Facts of the case
In the aftermath of September 11th, the FBI arrested thousands of Arab Muslim men as part of its investigation into the attacks. One of these men, Javaid Iqbal, was classified as being a high interestdetainee at the Metropolitan Detention Center in Brooklyn, New York. Iqbal claims that during his detention he was segregated from the rest of the prison population and mistreated in several ways, including confinement to a cell for 23 hours a day where he had blinding light shone on him constantly and air conditioning pumped into the cell even during the winter months. After being released, Iqbal brought a suit against representatives of the Department of Justice, Bureau of Prisons, and FBI alleging 21 violations of his statutory and constitutional rights based on his treatment while confined. These defendants argued that they should be protected from the suit in their official governmental roles through qualified immunity. The United States District Court for the Eastern District of New York denied the defendants’ motion to dismiss and rejected the qualified immunity defense.The U.S. Court of Appeals for the Second Circuit affirmed the district court’s rulings on all counts but one for violation of the right to due process. The Second Circuit noted that the actions taken by the government occurred in the immediate aftermath of September 11th and therefore created a unique context in which Iqbal’s claims had to be reviewed. Even with these circumstances, however, the court felt that the qualified immunity defense could protect the government only from the due process claim. The serious allegations of gross mistreatmentwere enough to sustain the remaining counts.
Why is the case important?
JavaidIqbal (P) was a Pakistani citizen who was arrested on criminal charges and detained by federal officials following the terrorist attack on 9/11. He filed suit against federal officials on the ground that his imprisonment was under conditions that infringed on his constitutional rights. The defendants moved the court to dismiss the complaint on grounds of facial insufficiency.
Does a complaint need to be non-conclusory, that is irrefutably supported by facts, plausible under the circumstances of the case and factually true, to be well-argued?
(Kennedy, J.) Yes. A well-pleaded complaint requires to be supported by allegations containing factual content which leads to the conclusion given, and have factual and plausible arguments which cannot be easily disproved. In this case, Iqbal (P) pleaded that the federal government had adopted a policy detaining all Arab Muslims after the terrorist attack of 9/11, until they were individually declared non-criminal by the FBI. It was claimed that this policy owed its origin to Ashcroft (D) and its adoption and widespread usage to Mueller (D). This allegation did not have factual content that would enable the court to come to the reasonable conclusion that the defendant actually is liable for the alleged misconduct. Moreover, the complaints were not plausible enough to raise the claim above the speculative level, but were mere conclusions. Even if an allegation is not supported by facts to the point of probability, the court requires more than conclusory statements. The facts which were required to support the complaints were not sufficiently provided. Thus the standards of pleading required in a complaint to avoid its dismissal, as set by this Court in the case of Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), were not met. The conclusory allegations against Ashcroft (D) and Mueller (D) were not such as would meet with instant belief nor were they supported by facts. Instead, the grounds for detention were plausible and did not violate the constitution. In his complaint, Iqbal (P) argued that Twombly set the standard only for cases of antitrust pleadings, but this argument is unsupported because Twombly sets the standard of good pleading for all civil cases. Iqbal’s (P) argument that Fed. R. Civ. P. 9(b) allows him to bring in general arguments rather than specific ones for an alleged violation of the constitution does not hold good, since the stated rule gives more flexibility to the pleading but does not take priority over Rule 8 which requires factual pleading instead Rule 9 (b) requires very specific factual support for the listed claims. The decision was reversed and the case remanded.
- Advocates: Gregory G. Garre Solicitor General, Department of Justice, argued the cause for the petitioners Alexander A. Reinert argued the cause for the respondents
- Petitioner: John D. Ashcroft, Former Attorney General, et al.
- Respondent: Javaid Iqbal et al.
- DECIDED BY:Roberts Court
- Location: MDC Brooklyn
|Citation:||556 US 662 (2009)|
|Granted:||Jun 16, 2008|
|Argued:||Dec 10, 2008|
|Decided:||May 18, 2009|