Sunday, November 24, 2013

Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit case brief

Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit case brief summary
507 U.S. 163 (1993)


CASE SYNOPSIS
Certiorari was granted to the United States Court of Appeals for the Fifth Circuit to decide whether a federal court was permitted to apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Fed. R. Civ. P. 8(a) -- in civil rights cases alleging municipal liability under 42 U.S.C.S. § 1983.

DISCUSSION

  • The Court reversed the judgment of the court of appeals, which affirmed the dismissal of petitioners' complaints alleging municipal liability under 42 U.S.C.S. § 1983 on the ground that petitioners failed to meet the "heightened pleading standard" required by the Fifth Circuit's decisional law. 
  • The Court concluded that federal courts were not permitted to apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Fed. R. Civ. P. 8(a) -- in civil rights cases alleging municipal liability under § 1983. 
  • The Court noted that Fed. R. Civ. P. 9(b) imposed a particularity requirement in only two specific instances, in averments of fraud or mistake, and did not impose a particularity requirement for complaints alleging municipal liability under § 1983. 
  • Thus, in the absence of amendment to the Federal Rules of Civil Procedure, federal courts and litigants had to rely on summary judgment and control of discovery to weed out unmeritorious § 1983 claims sooner rather than later.
CONCLUSION
The Court reversed a judgment affirming the dismissal of petitioners' complaints for failure to comply with heightened pleading requirements since the Federal Rules of Civil Procedure did not permit application of a heightened pleading standard in cases alleging municipal liability for constitutional injury.

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