Conley v. Gibson
Citation: 355 U.S. 41 (1957)
Facts
African-American railroad workers sued their union under the Railway Labor Act, alleging racial discrimination. The district court dismissed, finding the complaint insufficient. The Supreme Court reversed.
Issue
What standard governs the sufficiency of a complaint under the Federal Rules of Civil Procedure?
Holding
A complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that the plaintiff can prove no set of facts in support of the claim that would entitle relief. Liberal “notice pleading” requires only a short and plain statement of the claim.
Rule
No-set-of-facts standard (notice pleading): A complaint survives a motion to dismiss unless there is “no set of facts” that could entitle the plaintiff to relief. The complaint need not include detailed factual allegations; it need only give fair notice of the claim and the grounds on which it rests.
Overruled by: Bell Atlantic Corp. v. Twombly (2007) and Ashcroft v. Iqbal (2009) replaced this with the plausibility pleading standard — a complaint must plead factual content that allows the court to draw the reasonable inference that the defendant is liable.
Significance
- Defined the liberal notice-pleading standard that governed federal courts for 50 years
- Expressly overruled on the pleading standard by Twombly and Iqbal, though the “short and plain statement” requirement of FRCP 8(a)(2) remains
- Historical baseline for understanding how the pleading standard changed dramatically in 2007–2009