Wednesday, April 1, 2015

Ashcroft v. Iqbal case brief summary

Ashcroft v. Iqbal case brief summary
Posture: Scotus reversed appeals court. 
Facts: Plaintiff, a Pakistani Muslim man, filed discrimination suit against U.S. challenging detention in maximum security unit as a person of “high interest” during investigation of 9/11. 
Reasoning:  Justice Kennedy: Reiterated that to survive a motion to dismiss, a complaint must contain sufficient factual matter to state a claim to relief that is plausible on its face. Only a complaint with a plausible claim for relief survives a motion to dismiss. Where well pleaded complaints do not permit court to infer more than mere possibility the complaint but not shown that relief is right. Think that under Twombly, the complaint has not been made plausible. 
Conclusory allegations are not entitled to be assumed true. The allegations are conclusory in nature instead of extravagant or fanciful which disentitles them to presumption of truth. Claims also do not plausibly establish purpose of the alleged actions, which is important to prove discrimination. 
  1. Twombly is not limited to pleadings made in context of antitrust dispute. Twombly affects all cases
  2. Insufficient pleading does not turn on the control of discovery. It does not matter how lax discovery is, it still entitles people to burden of discovery. 
  3. Federal rules do not require courts to credit a complaint’s conclusory statements without references to factual context. Meaning that facts alleging the complaint are important and not the actual conclusion. 
Dissent: Justice Souter: Says that it does not matter if facts are crazy, or if they are probably not true, facts must be taken as true. The relevant question is whether, assuming factual allegations are true, plaintiff stated a ground for relief that is plausible. Says that there actually are enough facts to state a claim to relief that is plausible on its face. 

Dissent: Justice Breyer: Wants case management tools 

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