Civil Procedure I, Pages 391–400

Ashcroft v. Iqbal

Supreme Court of the United States, 2009

Facts:

In the wake of the 2001 attacks, the FBI detained plaintiff as one of 184 "high interest" individuals detained on immigration charges who were thought to be linked to the attacks. Plaintiff was placed in supermax prison, pleaded guilty, and was removed to his native Pakistan. He then filed an action against 34 federal officials for violating his constitutional rights.

Procedural History:

The District Court denied defendants motion, based on Conley. The Court of Appeals affirmed based on the newly-decided case of Twombly.

Issue:

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Did respondent, as the plaintiff in the District Court, plead factual matter that, if taken as true, states a claim that petitioners deprived him of his clearly established constitutional rights.

Plaintiff's Argument:

Defendants arrested and detained thousands of Arab Muslim men because of their race, religion, or national origin in the wake of September 11 attacks, and that they were given the harshest conditions because of their religion, race, and/or national origin, not a legitimate penological interest.

Defendant's Argument:

Plaintiff failed to state sufficient allegations to show their involvement in the unconstitutional conduct.

Rule:

Under Twombly a court need not accept legal conclusions as true, and only a complaint that states a plausible claim for relief survives a motion to dismiss.

Reasoning:

Plaintiff's claims were legal conclusions and not entitled to the assumption of truth. The evidence does not give a plausible showing, as a crackdown on people suspected to be linked to Al Qaeda and Osama bin Laden would naturally be mostly Arab Muslim men, even if they they weren't specially targeted. Plaintiff's complain does not even challenge the constitutionality of his arrest or detention regardless.

Holding:

Plaintiff did not plead factual matter than states a claim that defendants deprived him of his constitutional rights. Reversed and remanded.

Dissenting Opinions:

  • Souter: Plaintiff alleges that defendants knew of discrimination based on race, religion, and national origin, and actively acted to create it. These allegations are not too outlandish to be plausible, and other allegations added with them state a plausible entitlement to relief. They are not merely conclusory but state specific facts.

  • Breyer: In addition to Souter's dissent, lower level courts can begin discovery with lower level government officials to determine the validity before involving the higher level government officials.