Ashcroft v. Iqbal
173 L. Ed. 2d 868 · Supreme Court of the United States · 2009
Facts
Javaid Iqbal, a Pakistani Muslim, was arrested in the United States on criminal charges after the September 11, 2001, terrorist attacks and detained by federal officials. He was designated a "high interest" detainee and housed in the Administrative Maximum Special Housing Unit (ADMAX SHU) at the Metropolitan Detention Center (MDC) in Brooklyn, New York, under restrictive conditions. After pleading guilty, serving a term of imprisonment, and being removed to Pakistan, Iqbal filed a Bivens action against numerous federal officials, including former Attorney General John Ashcroft and FBI Director Robert Mueller. Iqbal's complaint alleged that Ashcroft and Mueller adopted an unconstitutional policy subjecting him to harsh conditions of confinement on account of his race, religion, or national origin, and that Ashcroft was the "principal architect" and Mueller "instrumental" in its adoption.
Procedural history
Iqbal filed a Bivens action in the United States District Court for the Eastern District of New York. Petitioners Ashcroft and Mueller moved to dismiss, raising qualified immunity, but the District Court denied their motion. Petitioners then filed an interlocutory appeal with the Court of Appeals for the Second Circuit, which affirmed the District Court's decision. The Supreme Court granted certiorari and reversed the Court of Appeals' judgment.
Issue
Did the respondent, as the plaintiff, plead sufficient factual matter that, if taken as true, states a plausible claim that petitioners (Ashcroft and Mueller) deprived him of his clearly established constitutional rights by purposefully adopting a discriminatory policy?
Holding
The Court held that respondent’s pleadings are insufficient. The complaint fails to plead sufficient facts to state a plausible claim for purposeful and unlawful discrimination against petitioners.
Rule
Under Federal Rule of Civil Procedure 8(a)(2), a complaint must contain sufficient factual matter, accepted as true, to "state a claim to relief that is plausible on its face," demanding more than "labels and conclusions" or a "formulaic recitation of the elements of a cause of action." The tenet that a court must accept all allegations as true is inapplicable to legal conclusions. For Bivens actions alleging invidious discrimination, a plaintiff must plead that each government official, through their own individual actions, acted with discriminatory purpose, meaning they undertook a course of action "because of," not merely "in spite of," its adverse effects on an identifiable group. Supervisory liability cannot be established solely on a theory of respondeat superior; purpose, rather than mere knowledge, is required to impose Bivens liability for unconstitutional discrimination.
Read the full opinion on CourtListener
Case brief last reviewed . Prepared by CaseReader from the published opinion.