Supreme Court summarily rejects heightened pleading requirement for civil rights plaintiffs
In Johnson v. City of Shelby, the entire Supreme Court recently addressed what is enough for civil rights plaintiffs to state a valid claim concerning alleged violations of constitutional rights. In a unanimous per curiam decision – meaning an opinion effectively authored by the entire Supreme Court – the Justices collectively considered the district court and court of appeals rulings against the plaintiffs and then decided as follows: “We summarily reverse.”
While rejecting the increasingly common defense that plaintiffs now must satisfy a heightened pleading standard to pursue their claims, the Supreme Court quoted long-standing legal authority as follows: “a basic objective of the rules is to avoid civil cases turning on technicalities.” In Johnson, the specific issue was whether the plaintiffs’ civil rights claims failed because the plaintiffs did not state the correct legal theory in their lawsuit. As to that question, the Supreme Court reiterated the rules of civil procedure “do not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim asserted.”
This ruling further bolsters the arguments long made by plaintiff counsel handling employment law, civil rights, and consumer protection cases. Specifically, the Supreme Court’s decisions in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009) have not really changed the legal standard for pursuing claims in court. In that regard, the Supreme Court’s unanimous per curiam ruling in Johnson is as concise as it is cogent in directing the district courts and appellate courts alike to reject the “gotchya litigation” tactics employed by certain defendants. In short, cases should be decided on their merits as a matter of law and fundamental fairness.