Ps allege that the Ds were negligent in executing search warrants on their residences.
Ps asserted the police conduct violated the 4th Amendment.
Ps pleadings did not meet the "heightened pleading standard" required by the Fifth Circuit.
Procedural History:
Lower court found for D.
TX Court of Appeals affirmed, found for D.
SCOTUS reversed, found for P, pleading valid.
Issues:
Can a federal court apply a "heightened pleading standard", more stringent than the usual pleading requirements of Rule 8(a) of the FRCP, in civil rights cases alleging municipal liability under 42 USC S1983?
Holding/Rule:
A federal court cannot apply a "heightened pleading standard" since Rule 8(a)(2) requires that a complaint contain only "a short and plain statement showing that the pleader is entitled to relief".
Reasoning:
The Ds had freedom from respondeat superior liability, but freedom from liability does not equate with freedom from suit.
It is impossible to square the "heightened pleading standard" applied by the Fifth Circuit with the liberal system of "notice pleading" set up by the Federal Rules.
If Rules 8 and 9 were rewritten, claims against municipalities under S1983 might be subject to the added specificity requirement of Rule 9(b). But that is a result that must come from amending the Federal Rules, not by judicial interpretation.
Federal courts and litigants must rely on summary judgment and control of discovery to weed out claims without merit sooner rather than later.
Dissent:
None.
Notes:
S1983 requires a policy that goes against civil rights since the municipality was immune from respondeat superior liability.
The window for suit under S1983 is already so narrow that the heightened pleading standard is not necessary.
