Samuel Lewis, et al. v. Hilltop Group, L.P., et al.

Summary

The United States District Court for the Northern District of California partially grants and partially denies Plaintiffs’ motion to strike Defendants’ seventeen affirmative defenses. The court declines to apply the Twombly/Iqbal pleading standard to affirmative defenses but strikes defenses concerning failure to state a cause of action, reasonable accommodation, business necessity, legal necessity, and reservation of additional defenses, without leave to amend.

Holdings

1. Affirmative defenses are subject to the fair-notice standard and need not satisfy the heightened pleading requirements of Twombly and Iqbal.
2. The court declined to strike the remaining affirmative defenses merely because they were pleaded in generalized or boilerplate fashion, because Plaintiffs had not shown that the defenses were so clearly insufficient as to fail the fair-notice standard or that striking them would meaningfully streamline the litigation.
3. A defense asserting that the plaintiff failed to state a cause of action or failed to establish a reasonable accommodation is not an affirmative defense when it merely challenges the plaintiff's prima facie case, and those defenses were stricken without leave to amend.
4. A reservation of the right to assert additional unspecified affirmative defenses later is not itself an affirmative defense and was properly stricken without leave to amend.
5. The Business Necessity and Legal Necessity defenses were irrelevant to the claims at issue and were stricken without leave to amend.

Questions Presented

1. Whether affirmative defenses must satisfy the heightened pleading standard of Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, or only the fair-notice standard.
2. Whether the defenses labeled Failure to State a Cause of Action and Reasonable Accommodation were improper because they challenged Plaintiffs' prima facie case rather than constituted affirmative defenses.
3. Whether a reservation of the right to assert additional unspecified defenses was itself an affirmative defense.
4. Whether the Business Necessity and Legal Necessity defenses were irrelevant to the claims pleaded.

Disposition

other