Tuesday, October 25, 2011

Ashcroft v. Iqbal case brief (129 S.Ct. 1937)

ASHCROFT v IQBAL
129 S.Ct. 1937 (2009)

FACTS
Respondent is resident of Pakistan and Muslim. After 9/11 attacks, arrested in US on criminal charges and detained by federal officials in Brooklyn NY. “High Interest”. Alleges that the two petitioners adopted an unconstitutional policy that subjected respondent to harsh conditions on account of his race, religion, or national origin. 23 hours a day in cell, one hour out in cuffs/irons, 4 officer escort.

PROCEDURAL HISTORY

-Petitioners: Qualified immunity - motion to dismiss (district court denied motion)
-Brought interlocutory appeal in Court of Appeals 2nd circuit. Assumed jurisdiction - affirmed Dist. Court’s decision.
-Respondent's account of his prison ordeal could, if proved, demonstrate unconstitutional misconduct by some government actors. (allegations in regards to these actors not here)

ISSUE

Did respondent (as Pl. in dist. court) plead factual matter that, if taken as true, states a claim that petitioners deprived him of his clearly established constitutional rights?

HOLDING

Respondent’s pleadings are insufficient.

SUBISSUE 1

Did Court of Appeals have subject-matter jurisdiction to affirm the District Court’s order denying petitioners’ motion to dismiss? --Yes.
“collateral-order doctrine”

SUBISSUE 2

The elements a plaintiff must plead to state a claim of unconstitutional discrimination against officials entitled to assert the defense of qualified immunity.

RULES

Respondeat superior- Government officials may not be held liable for the unconstitutional conduct of their subordinates.
-Pl. must plead that each Government official defendant, through the official’s own actions, has violated the Constitution.
Pl. must plead and prove that def. acted with discriminatory purpose.
[It follows that, to state a claim based on a violation of a clearly established right, respondent must plead sufficient factual matter to show that petitioners adopted and implemented the detention polices at issue not for a neutral, investigative reason but for the purpose of discrimination on account of race, religion, or national origin.

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