Ashcroft v. Iqbal Supreme Court of the United States 556 U.S. 662 (2009) p. 385 Facts Iqbal is citizen of Pakistan and a Muslim. Following 9/11, U.S. officials, including petitioners Mueller and Ashcroft, as part of FBI, investigated suspected terrorists. 184 people were deemed to be of “high interest” and were held in facilities with restricted access to the outside world and to other prisoners. Iqbal was one of these individuals. Sued federal officials for designating him as person of “high interest” on account of his race, religion, or national origin which violated his First and Fifth Amendment rights in the Constitution. Procedural History In District Court, petitioners raised defense of qualified immunity and moved to dismiss suit. District Court denied motion to dismiss, concluding complaint was sufficient to state a claim. Petitioners brought interlocutory appeal to the Court of Appeals for the Second Circuit, which affirmed District Court’s decision, finding that the complaint did not need “amplification”. Issue Presented Does a complaint alleging that members of the FBI were aware of discrimination and confinement of Muslim citizens sufficient to state a claim? Arguments Presented Iqbal -decision in Twombly should be limited to antitrust disputes -Construction of Rule 8 should be tempered by limiting discovery to petitioner’s qualified immunity -Federal Rules under Rule 9b explicitly allow Iqbal to allege petitioner’s discrimination “generally” Rule Legal conclusions do not have to be accepted as true by court; only a complaint that states a plausible claim for relief survives motion to dismiss. Legal conclusions must be supported by factual allegations. Reasoning Iqbal’s allegations that petitioners “knew of, condoned, and willfully and maliciously agreed to subject him to harsh conditions of confinement” on account of his race, religion, and national origin. This a “formulaic recitation of elements” and conclusory. Iqbal must show facts that the purpose of the government officials in holding the detainees was because of their race, religion, or national origin. Saying that detainees were housed in “restrictive conditions of confinement” until they were “cleared” by the FBI is not a fact that connects this to the FBI’s purpose being to hold the detainees solely on the basis of their race, religion, or national origin”. Important to preserve government officials qualified immunity. Federal Rules do not require court to credit a complaint’s conclusory statements without reference to its factual content; Rule 9 does not render Rule 8 inapplicable. 2 Prong test: disregard conclusory allegations  determine plausibility of nonconclusory allegations Holding Iqbal’s complaint fails to sufficiently state a claim. Judgement Reversed and remanded for Court of Appeals to decide whether to remand to District Court so that respondent can seek leave to amend deficient complaint. Dissent -Complaint alleges that Mueller and Ashcroft were at least aware of policies creating discrimination, but also goes further to say they actively promulgated such policies -Plausibility interpreted incorrectly by majority: must be something outlandish, doesn’t require court to determine if it is probably true -Iqbal detailed specific discriminatory policy- this is not too general