Swierkiewicz v. Sorema N.A.

534 U.S. 506, 122 S. Ct. 992 (2002)



Fed. R. Civ. P. 8(a)(2) provides that a complaint must include only a short and plain statement of the claim showing that the pleader is entitled to relief. Such a statement must simply give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests. This simplified notice pleading standard relies on liberal discovery rules and summary judgment motions to define disputed facts and issues and to dispose of unmeritorious claims.


A 53-year-old native of Hungary, filed a suit against his former employer, alleging that he had been fired on account of his national origin and his age in violation of Title VII of the Civil Rights Act of 1964 and the Age Discrimination in Employment Act of 1967 (ADEA), respectively. The trial court dismissed the compliant. On appeal, the trial courts decision was affirmed on the ground that employment discrimination complaint required the employee to allege facts constituting prima facie discrimination and the employee's allegations were insufficient as a matter of law to raise an inference of discrimination. The case was elevated to the Supreme Court of the United States on certiorari.


Was the complaint sufficient to state a claim?




The Court held that an employment discrimination complaint need not contain specific facts establishing a prima facie case under the McDonnell Douglas framework, but instead must contain only "a short and plain statement of the claim showing that the pleader is entitled to relief," Fed. Rule Civ. Proc. 8(a)(2). The Court further held that the complaint satisfied the requirements of Fed. R. Civ. P. 8(a) because it gave the employer fair notice of the basis for the claims. The employee alleged that he was terminated on account of his national origin and age. His complaint also detailed the events leading to his termination, provided relevant dates, and included the ages and nationalities of at least some of the relevant persons involved with his termination. The Court concluded that the allegations stated claims upon which relief could be granted.

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