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Johnson v. City of Shelby

Supreme Court of the United States
Nov 10, 2014
574 U.S. 10 (2014)

Summary

holding that plaintiffs were not required to invoke § 1983 in order to state a claim

Summary of this case from Riddick v. United States

Opinion

No. 13–1318.

11-10-2014

Tracey L. JOHNSON, et al. v. CITY OF SHELBY, MISSISSIPPI.


Plaintiffs below, petitioners here, worked as police officers for the city of Shelby, Mississippi. They allege that they were fired by the city's board of aldermen, not for deficient performance, but because they brought to light criminal activities of one of the aldermen. Charging violations of their Fourteenth Amendment due process rights, they sought compensatory relief from the city. Summary judgment was entered against them in the District Court, and affirmed on appeal, for failure to invoke Rev. Stat. § 1979; 42 U.S.C. § 1983, in their complaint. We summarily reverse. Federal pleading rules call for " a short and plain statement of the claim showing that the pleader is entitled to relief," Fed. Rule Civ. Proc. 8(a)(2) ; they do not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim asserted. See Advisory Committee Report of October 1955, reprinted in 12A C. Wright, A. Miller, M. Kane, R. Marcus, & A. Steinman, Federal Practice and Procedure 644 (2014) (Federal Rules of Civil Procedure "are designed to discourage battles over mere form of statement"); 5 C. Wright & A. Miller, Federal Practice and Procedure § 1215, p. 172 (3d ed. 2004) ( Rule 8(a)(2) "indicates that a basic objective of the rules is to avoid civil cases turning on technicalities"). In particular, no heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke § 1983 expressly in order to state a claim. See Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 164, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993) (a federal court may not apply a standard "more stringent than the usual pleading requirements of Rule 8(a)" in "civil rights cases alleging municipal liability"); Swierkiewicz v. Sorema N. A., 534 U.S. 506, 512, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002) (imposing a "heightened pleading standard in employment discrimination cases conflicts with Federal Rule of Civil Procedure 8(a)(2)").

The Fifth Circuit defended its requirement that complaints expressly invoke § 1983 as "not a mere pleading formality." 743 F.3d 59, 62 (2013) (internal quotation marks omitted). The requirement serves a notice function, the Fifth Circuit said, because "[c]ertain consequences flow from claims under § 1983, such as the unavailability of respondeat superior liability, which bears on the qualified immunity analysis." Ibid. This statement displays some confusion in the Fifth Circuit's perception of petitioners' suit. No "qualified immunity analysis" is implicated here, as petitioners asserted a constitutional claim against the city only, not against any municipal officer. See Owen v. Independence, 445 U.S. 622, 638, 100 S.Ct. 1398, 63 L.Ed.2d 673 (1980) (a "municipality may not assert the good faith of its officers or agents as a defense to liability under § 1983").

Our decisions in Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007), and Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009), are not in point, for they concern the factual allegations a complaint must contain to survive a motion to dismiss. A plaintiff, they instruct, must plead facts sufficient to show that her claim has substantive plausibility. Petitioners' complaint was not deficient in that regard. Petitioners stated simply, concisely, and directly events that, they alleged, entitled them to damages from the city. Having informed the city of the factual basis for their complaint, they were required to do no more to stave off threshold dismissal for want of an adequate statement of their claim. See Fed. Rules Civ. Proc. 8(a)(2) and (3), (d)(1), (e). For clarification and to ward off further insistence on a punctiliously stated "theory of the pleadings," petitioners, on remand, should be accorded an opportunity to add to their complaint a citation to § 1983. See 5 Wright & Miller, supra, § 1219, at 277–278 ("The federal rules effectively abolish the restrictive theory of the pleadings doctrine, making it clear that it is unnecessary to set out a legal theory for the plaintiff's claim for relief." (footnotes omitted)); Fed. Rule Civ. Proc. 15(a)(2) ("The court should freely give leave [to amend a pleading] when justice so requires.").

* * *

For the reasons stated, the petition for certiorari is granted, the judgment of the United States Court of Appeals for the Fifth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.

It is so ordered.


Summaries of

Johnson v. City of Shelby

Supreme Court of the United States
Nov 10, 2014
574 U.S. 10 (2014)

holding that plaintiffs were not required to invoke § 1983 in order to state a claim

Summary of this case from Riddick v. United States

holding that the plaintiffs’ had pleaded a substantively plausible claim when they "stated simply, concisely, and directly events that, [the plaintiffs] alleged, entitled them to damages"

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holding that a plaintiff's complaint need allege only enough facts to establish a colorable issue of federal law and need not cite a particular provision

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holding that it was improper for a district court to dismiss a complaint simply because the complaint referred to the Fourteenth Amendment instead of 42 U.S.C. § 1983

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holding that federal pleading rules do not require a perfect statement of the legal theory supporting the claim asserted

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holding that “no heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke § 1983 expressly in order to state a claim”

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holding a complaint need not cite § 1983 to state a § 1983 claim

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holding that plaintiffs' failure to specifically invoke § 1983 did not render their complaint deficient

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holding that plaintiffs did not need to specifically invoke 28 U.S.C. § 1983 in their complaint

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finding that no heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke §1983 expressly in order to state a claim.

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finding that no heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke §1983 expressly in order to state a claim.

Summary of this case from Zickes v. Cuyahoga Cnty.

finding complaint satisfied Twombly and Iqbal because it "stated simply, concisely, and directly events that, [plaintiffs] alleged, entitled them to damages from the [defendant]"

Summary of this case from Farm & Trade, Inc. v. Farmtrade, LLC

reversing a grant of summary judgment for defendants that was premised on the plaintiffs' failure to invoke the specific statute at issue

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reversing dismissal for failure to invoke proper statute in complaint

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Case details for

Johnson v. City of Shelby

Case Details

Full title:Tracey L. JOHNSON, et al. v. CITY OF SHELBY, MISSISSIPPI.

Court:Supreme Court of the United States

Date published: Nov 10, 2014

Citations

574 U.S. 10 (2014)
135 S. Ct. 346
190 L. Ed. 2d 309
90 Fed. R. Serv. 3d 224

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