Case

Ashcroft v. Iqbal

Answer: Ashcroft v. Iqbal, 556 U.S. 662 (2009). The Court adopted a two-step Rule 12(b)(6) analysis (disregard legal conclusions; then test plausibility), held that Bivens/§1983 liability is not vicarious and requires each official’s own misconduct, and required purposeful discrimination for constitutional discrimination claims, making the detainee’s allegations insufficient.

Rule to remember

Ashcroft v. Iqbal (2009) established the Twombly/Iqbal plausibility standard for Rule 12(b)(6) motions and clarified that Bivens/§1983 liability is not based on supervisory status; each official is liable only for their own misconduct, and constitutional discrimination claims require purposeful discrimination.

Key elements and checks

In the source’s words

“Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.”

ASHCROFT v. IQBAL (Opinion of the Court) | LII

“Government officials may not be held liable for the unconstitutional conduct of their subordinates under a theory of respondeat superior.”

ASHCROFT v. IQBAL (Opinion of the Court) | LII

Federal pleading standards in Iqbal interpret Rule 8(a) and govern federal courts. State pleading standards vary by jurisdiction; some states retain more notice-pleading oriented regimes. Also, Bivens remedies are narrowly confined and rarely extended beyond established contexts.

Sources