Case
Bell Atlantic Corp. v. Twombly
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), holds that a complaint must include enough factual matter to state a claim to relief that is plausible on its face. Parallel conduct plus a bare conspiracy label is not enough. The Court moved beyond the Conley “no set of facts” dictum under Rule 8(a)(2)/12(b)(6).
Rule to remember
Bell Atlantic Corp. v. Twombly (2007) established the federal “plausibility” pleading standard: a complaint must contain enough factual matter to state a claim that is plausible on its face; labels, conclusions, and formulaic recitations do not suffice.
Key elements and checks
- Rule 8(a)(2) demands a short and plain statement showing entitlement to relief, but with enough facts to suggest liability, not mere conclusions.
- Courts disregard conclusory allegations and assess well-pleaded factual allegations for plausibility.
- Plausibility requires more than possibility; it does not require probability.
- Antitrust §1 claims need facts suggesting agreement; parallel conduct alone is insufficient.
- The decision disapproved reliance on the “no set of facts” dictum from earlier precedent.
- Not a heightened particularity rule; it simply requires factual enhancement sufficient for a reasonable inference of liability.
In the source’s words
“only enough facts to state a claim to relief that is plausible on its face.”
BELL ATLANTIC CORP. v. TWOMBLY (Opinion/Syllabus) — LII
“Because the plaintiffs here have not nudged their claims across the line from conceivable to plausible, their complaint must be dismissed.”
BELL ATLANTIC CORP. v. TWOMBLY (Opinion/Syllabus) — LII
Twombly governs federal pleading. State pleading standards can differ: some model their rules on the Federal Rules, while others vary. Always check the forum’s rules and controlling state cases.