Imperfect statement of legal theory doesn't justify dismissal of cops' suit, SCOTUS rules
Failure to cite Section 1983 in a suit for alleged due-process violations doesn’t doom a suit by fired police officers, the U.S. Supreme Court ruled Monday in a summary reversal.
The per curiam opinion (PDF) said federal pleading rules call for a short and plain statement of the claim, but they don’t “countenance dismissal of a complaint for imperfect statement of the legal theory” that supports the claim.
The officers had claimed in a suit against the city of Shelby, Mississippi, that they were fired because they brought to light one alderman’s criminal activity. The suit alleged violation of due-process rights but did not cite Section 1983 of the Civil Rights Act. A trial judge and the New Orleans-based 5th U.S. Circuit Court of Appeals said the failure required dismissal of the suit.
The Supreme Court reversed in a short opinion that distinguished between insufficient facts in a pleading and imperfect statement of legal theory.
The Supreme Court said the 2007 decision Bell Atlantic Corp. v. Twombly and the 2009 decision Ashcroft v. Iqbal concerned factual allegations needed to survive a motion to dismiss.
In the present case, the police officers’ complaint was not deficient in regard to the statement of facts, the opinion said. “Petitioners stated simply, concisely, and directly events that, they alleged, entitled them to damages from the city,” the Supreme Court said. “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.”
The officers should be allowed to add a citation to Section 1983 on remand, the Supreme Court said.