US Supreme Court: Statement of the Legal Theory Supporting a Claim Is Not Required in a Pleading
The US Supreme Court recently emphasized that pleadings under the Federal Rules of Civil Procedure do not require a statement of the legal theory supporting the claim. In Johnson v. City of Shelby, 135 S. Ct. 346 (U.S. 2014), the plaintiffs were former police officers of the City of Shelby, Mississippi, who filed suit against the city claiming they were unlawfully fired because they uncovered criminal activity by a city Alderman. The District Court granted summary judgment against the plaintiffs, ruling their Complaint failed to cite the applicable statute for their cause of action, 42 U.S.C. § 1983. The Fifth Circuit affirmed, holding the invocation of § 1983 in the Complaint was “not a mere pleading formality,” but a notice requirement as “[c]ertain consequences flow from claims under § 1983.” 743 F. 2d 59, 62 (5th Cir. 2013).
The Supreme Court reversed, holding the Complaint’s failure to invoke § 1983 did not warrant dismissal. The Court emphasized that Rule 8(a)(2) of the Federal Rules of Civil Procedure requires only a “short and plain statement for the claim showing that the pleader is entitled to relief.” Johnson, 135 S. Ct. at 346 (citing Fed. R. Civ. P. 8(a)(2)). The Court noted that its decisions in Bell Atlantic Corp. v. Twombly, 127 S. Ct. 1955 (2007) and Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) were not applicable “for they concern the factual allegations a complaint must contain to survive a motion to dismiss.” Id. at 347 (emphasis in original). It found the plaintiffs’ Complaint was not factually deficient because it stated, “simply, concisely, and directly events that, they alleged, entitled them to damages from the city.” Id. The Court held the Rules “do not countenance dismissal of a complaint for imperfect statement the legal theory supporting the claim asserted.” Id. at 346. As such, “Having informed the city of the factual basis for their complaint, [plaintiffs] were required to do no more to stave off threshold dismissal for want of an adequate statement of their claim.” Id.
— Paul M. Ellis