Ashcroft v. Iqbal
556 U.S. 662 (2009)
Iqbal was a citizen of Pakistan. He was arrested and detained by federal officials that were investigating the September 11th terrorist attacks.
- He claimed that his treatment while in detention violated his constitutional rights.
- Along with others, FBI Director Mueller, and Attorney General Ashcroft were included in the suit:
- They designated Iqbal a person of high interest based on his race, religion, and national origin.
- They approved the highly restrictive conditions and basically headed the policy.
- Thousands of Arab Muslim men were also arrested and detained.
- The district court denied the motion to dismiss, relying on the Conley standard – “it cannot be said that there is no set of facts on which Iqbal would be entitled to relief.”
- The Court of Appeals found the pleading adequate, stating that the Twombly standard was NOT universally applicable:
- It only applied to complex cases where additional facts are needed to determine the plausibility of the claim.
- Here, Iqbal’s claim was straightforward and not subject to it.
Was Iqbal’s complaint adequate?
No. Case reversed and remanded.
- Iqbal’s complaint simply recited the elements of his claim, and was too conclusory to be assumed true.
- He needed to provide facts plausibly showing that Ashcroft purposefully adopted the policy because of race, religion, or national origin.
- The court held that his complaint only plausibly suggested that law enforcement, in the aftermath of a devastating terrorist attack, sought to detain suspected terrorists, which doesn’t violate constitutional rights.
- As you can see, this was their “competing inference” that was found in the anti-trust, Twombly case, so more facts were needed.
- The ruling misunderstood the Twombly standard:
- In a motion to dismiss, the court isn’t supposed to consider whether the allegations are probably true – they are supposed to take them as true.
- Here, the allegations in the complaint weren’t legal conclusions or inconsistent with legal conduct, as was the case in Twombly (where competing theories were present).
- “Ashcroft and Mueller were given fair notice of what the claim is and the grounds upon which it rests.”
Two Prongs of the Twombly-Iqbal test (Plausible Pleading):
1. Take the factual allegations of the complaint as true.
- However, ONLY done if complaint is well-pleaded, and NOT conclusory.
2. Determine whether the allegations plausibly give rise to an entitlement of relief.
- This view seems to break from Conley, in that competing inferences appear to cancel out.
* This is somewhat unsettled law, so lessons to be taken from these cases and Iqbal itself are:
- If you’re a plaintiff, err on the side of fact pleading.
- If you’re a defendant, target any remotely conclusory allegation.