Ashcroft v Iqbal - Case Brief PDF

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CITATION: Ashcroft v Iqbal, 556 US 663 (2009) FACTS:  Iqbal and Arab Muslim from Pakistan  After 9/11 he was arrested and detained by fed officials, Ashcroft (Attorney Gen) and Mueller (FBI Director)  P made claim for violation of fed constitutional rights by fed officials (Bivens claim)  P alleged Ds violated his 1st and 5th amendment rights by adopting policies that led to his designation as a person of high interest and by subjecting him to harsh conditions of confinement b/c of his race, religion, or nat’l origin  P alleged Ashcroft was principal architect of this policy and Mueller was instrumental in executing it  P also alleged that FBI arrested and detained thousands of Arab Muslim men as part of investigation of the events of 9/11 o Held post 9/11 detainees in highly restrictive conditions of confinement until they were clear by FBI (approved by Mueller and Ashcroft) ISSUE:  Whether a complaint needs to be non-conclusory to state a claim? HOLDING: Yes. Trial decision reversed and remanded. PROCEDURE: P sued D for violation of 1st and 5th amendment rights. D moved to dismiss for lack of. Trial court denied. D appealed. Court of appeals also denied. D petitioned writ cert, which was granted. USSC reversed and remanded lower court decisions. RULE OF LAW: Under Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), a complaint will only survive a motion to dismiss if it alleges non-conclusory facts that, taken as true, state a claim to relief that is plausible on its face. REASONING:  Ps claim amount to formulaic recition of a elements of constitutional discrimination claim, but these are merely conclusory, and don’t need to be assumed true  More likely explanations for arrest and detainment than purposefully designating detainees of high interest b/c of race religion, or national origin  Arrests were justified by Mueller b/c of nondiscriminatory intentto detain aliens who were illegally present in US and who had potential connections to those who committed terrorist attacks  Ps complaint doesn’t challenge the constitutionality or the initial detention; they rest solely on policy of holding post 9/11 detainees once they were categorized as high risk o Doesn’t show it was done b/c of race religion nat’l origin

CONCURRING/DISSENT:  Souter, Stevens, Breyer, Ginsburg: Twombly was distinguishable b/c involved antitrust conspiracy based on parallel conduct that was consistent w/ lawful business behavior. Here the allegations of the complaint are neither confined to naked legal conclusions not consistent with legal conduct COMMENTS: Purpose of case is to show that plausibility standard from Twombly is not limited to antitrust cases. Applicable to all civil cases....