Bell Atlantic Corp. v. Twombly

Summary

The U.S. Supreme Court held that a complaint alleging a Sherman Act § 1 conspiracy based primarily on parallel conduct must include sufficient factual matter to plausibly suggest an agreement. The Court rejected conclusory allegations and retired the “no set of facts” pleading language from Conley v. Gibson, reversing the Second Circuit and affirming dismissal of the complaint.

Holdings

1. A complaint must contain enough factual matter, accepted as true, to suggest that an agreement was made and to state a claim for relief that is plausible on its face. Labels, conclusions, and a formulaic recitation of the elements are insufficient.
2. Allegations of parallel conduct, even consciously undertaken, do not by themselves state a § 1 conspiracy claim; they must be placed in a context that raises a plausible suggestion of a preceding agreement rather than independent action.
3. The complaint failed to state a valid § 1 claim because its allegations did not plausibly suggest an agreement among the incumbent carriers.
4. The 'no set of facts' language from Conley v. Gibson should be retired as an incomplete statement of the pleading standard and is not the governing test for whether a complaint survives a motion to dismiss.

Questions Presented

1. What must a complaint allege to state a claim under § 1 of the Sherman Act based on parallel conduct?
2. Whether the plaintiffs' allegations of parallel conduct and an asserted agreement not to compete plausibly suggested an unlawful agreement sufficient to survive a Rule 12(b)(6) motion.
3. Whether the 'no set of facts' language from Conley v. Gibson remained the governing formulation for evaluating the sufficiency of a complaint.

Disposition

reversed_and_remanded