Conley v. Gibson

Conley v. Gibson

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Encyclopedia
Conley v. Gibson, 355 U.S. 41 (1957), was a case decided by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 that provided a basis for a broad reading of the "short plain statement" requirement for pleading
Pleading
In law as practiced in countries that follow the English models, a pleading is a formal written statement filed with a court by parties in a civil action, other than a motion...

 under Rule 8 of the Federal Rules of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...

.

Opinion of the Court


The case arose from an alleged wrongful discharge of African-American employees from a railroad company and unequal protection from the union. The court ruled that general allegations of discrimination were sufficient to fulfill the Rule 8 requirement of a "short plain statement" because liberal discovery guidelines allowed the complaint
Complaint
In legal terminology, a complaint is a formal legal document that sets out the facts and legal reasons that the filing party or parties In legal terminology, a complaint is a formal legal document that sets out the facts and legal reasons (see: cause of action) that the filing party or parties In...

 to gain much more specificity before trial. The kind of pleading allowed by Conley was known as "notice pleading."

Conley Presumptions:
1) Plaintiff's allegations are true
2) Facts are construed as most favorable to the plaintiff
3) Cannot dismiss case unless proven beyond a doubt that plaintiff can prove no set of facts

Subsequent developments


In 2007, the United States Supreme Court overruled Conley, creating a new, stricter standard of a pleading's required specificity. Under the standard the Court set forth in Conley, a complaint need only state facts which make it "conceivable" that it could prove its legal claims -- that is, that a court could only dismiss a claim if it appeared, beyond a doubt, that the plaintiff would be able to prove "no set of facts" in support of her claim that would entitle her to relief. In Bell Atlantic Corp. v. Twombly
Bell Atlantic Corp. v. Twombly
Bell Atlantic Corp. v. Twombly, , was a decision of the Supreme Court of the United States involving anti-trust law and civil procedure. Authored by Justice David Souter, it established that parallel conduct, absent evidence of agreement, is insufficient to sustain an anti-trust action under § 1...

, the court adopted a more strict, "plausibility" standard, requiring in this case "enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of illegal agreement." The Twombly reading was upheld in Ashcroft v. Iqbal
Ashcroft v. Iqbal
Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937 , was a case in which the United States Supreme Court held that top government officials were not liable for the actions of their subordinates absent evidence that they ordered the allegedly discriminatory activity...

in 2009.