Ashcroft v. Iqbal
Citation: 556 U.S. 662 (U.S. Supreme Court, 2009)
Facts
Javaid Iqbal, a Pakistani Muslim, was arrested after the September 11 attacks and held in a maximum-security facility. He filed a Bivens action against Attorney General John Ashcroft and FBI Director Robert Mueller, alleging they had adopted a policy of detaining Arab Muslim men on account of race, religion, and national origin. The district court denied defendants’ motion to dismiss, and the Second Circuit affirmed.
Issue
Whether Iqbal’s complaint contained sufficient factual matter to state a plausible claim that the defendant officials personally adopted a discriminatory detention policy.
Holding
The Supreme Court reversed, holding that Iqbal’s complaint failed to plead sufficient facts to plausibly show that Ashcroft and Mueller had acted with discriminatory purpose, and that conclusory allegations of intentional discrimination were not entitled to the assumption of truth.
Rule
Twombly’s plausibility pleading standard applies to all civil actions in federal court, not just antitrust cases. Courts must (1) identify pleadings that are not entitled to the assumption of truth because they are conclusory, and (2) determine whether the remaining factual allegations plausibly give rise to an entitlement to relief.
Significance
Iqbal extended Twombly beyond antitrust to all civil litigation, cementing the two-step plausibility analysis as the universal standard for 12(b)(6) motions. Together, Twombly and Iqbal (often cited as “Twiqbal”) represent the most significant shift in federal pleading doctrine in decades.