Leatherman v. Tarrant County Narcotics

507 U.S. 163, 113 S. Ct. 1160 (1993)

 

RULE:

The Federal Rules of Civil Procedure do not require a claimant to set out in detail the facts upon which he bases his claim. To the contrary, all the Rules require is "a short and plain statement of the claim" that will give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests.

FACTS:

The District Court dismissed plaintiffs' complaints alleging municipal liability under 42 U.S.C.S. § 1983 on the ground that plaintiffs failed to meet the "heightened pleading standard" required by the Fifth Circuit's case law. The Circuit Court of Appeals affirmed, holding that federal courts were permitted to apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Fed. R. Civ. P. 8(a) -- in civil rights cases alleging municipal liability under § 1983

ISSUE:

Can a federal court may apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Rule 8(a) of the Federal Rules of Civil Procedure -- in civil rights cases alleging municipal liability under Rev. Stat. § 1979, 42 U. S. C. § 1983?

ANSWER:

No.

CONCLUSION:

A federal court may not apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Federal Rule of Civil Procedure 8(a) -- in civil rights cases alleging municipal liability under § 1983. First, the heightened standard cannot be justified on the ground that a more relaxed pleading standard would eviscerate municipalities' immunity from suit by subjecting them to expensive and time-consuming discovery in every § 1983 case. Municipalities, although free from respondeat superior liability under § 1983, not enjoy absolute or qualified immunity from § 1983 suits. Second, it is not possible to square the heightened standard applied in this case with the liberal system of "notice pleading" set up by the Federal Rules. Rule 8(a)(2) requires that a complaint include only "a short and plain statement of the claim showing that the pleader is entitled to relief. " And while Rule 9(b)requires greater particularity in pleading certain actions, it does not include among the enumerated actions any reference to complaints alleging municipal liability under § 1983.

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