Summary
The Supreme Court held that a complaint asserting unconstitutional discrimination by federal officials must plead sufficient factual matter to state a plausible claim for relief. The Court rejected supervisory liability based solely on knowledge or acquiescence and concluded that the defendants' qualified-immunity appeal was immediately appealable under the collateral-order doctrine. The Court reversed the Second Circuit's decision finding the complaint sufficient.
Topics
Practice areas
Questions Presented
- Whether the Court of Appeals had interlocutory jurisdiction under the collateral-order doctrine to review the denial of petitioners' qualified-immunity-based motion to dismiss.
- Whether Iqbal's complaint pleaded sufficient factual matter under Federal Rule of Civil Procedure 8(a)(2) to state a plausible Bivens claim for purposeful unconstitutional discrimination against Ashcroft and Mueller.
- Whether federal officials may be held liable under Bivens for the unconstitutional conduct of subordinates based solely on supervisory status, knowledge, or respondeat superior.
Holdings
- A district court order denying qualified immunity at the motion-to-dismiss stage is immediately appealable under the collateral-order doctrine when the appeal presents an abstract legal question, including whether the complaint sufficiently alleges a clearly established constitutional violation.
- To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim for relief that is plausible on its face; legal conclusions and conclusory recitations of the elements are not entitled to the assumption of truth.
- In a Bivens action, each government official is liable only for the official's own unconstitutional conduct; liability may not be imposed solely through respondeat superior or a supervisor's knowledge of a subordinate's discriminatory purpose.
- Iqbal's complaint failed to plead sufficient facts to state a plausible claim that Ashcroft and Mueller purposefully adopted or implemented the detention policies because of race, religion, or national origin.
Key quotations
“To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.”” (678)
“When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” (679)
“Absent vicarious liability, each Government official, his or her title notwithstanding, is only liable for his or her own misconduct.” (676-677)
Factual background
After the September 11, 2001 attacks, Javaid Iqbal, a Pakistani Muslim, was arrested on federal fraud-related charges and detained at the Metropolitan Detention Center in Brooklyn. He was designated a high-interest detainee and held in the Administrative Maximum Special Housing Unit under highly restrictive conditions. Iqbal alleged that Ashcroft and Mueller adopted or approved policies that subjected him and other Arab Muslim detainees to those conditions because of race, religion, or national origin.
Procedural history
Iqbal sued numerous federal officials under Bivens, alleging that Ashcroft and Mueller adopted a discriminatory detention policy. The Eastern District of New York denied their Rule 12(b)(6) motion, and the Second Circuit affirmed. The Supreme Court held that the interlocutory appeal was within the collateral-order doctrine, reversed the judgment, and remanded for further proceedings, including consideration of whether Iqbal should receive leave to amend.
Remand instructions
The Court of Appeals was directed to determine in the first instance whether to remand to the District Court so that Iqbal could seek leave to amend his deficient complaint.