Ashcroft v. Iqbal

Facts

After the September 11, 2001, terrorist attacks, the FBI questioned more than 1,000 people. Some 762 were held on immigration charges, and a subset of 184 was deemed of high interest. Javaid Iqbal, a citizen of Pakistan and a Muslim, was one of the detainees. According to his complaint, federal agents arrested him in November 2001 on charges of fraud in relation to identification documents and conspiracy to defraud the United States. While awaiting trial at the Metropolitan Detention Center in Brooklyn, he was designated a person of high interest. In January 2002 he was placed in the Administrative Maximum Special Housing Unit, where detainees were locked down 23 hours a day. He later brought a Bivens action, a suit for damages against federal officers for violating constitutional rights. The complaint focused on his treatment in the special unit, not his arrest. It claimed that Ashcroft, the former Attorney General, and Mueller, the FBI Director, designated him a person of high interest because of his race, religion, or national origin, in violation of the First and Fifth Amendments. It alleged that the FBI, under Mueller's direction, arrested and detained thousands of Arab Muslim men, and that the two approved a policy of holding post-September-11 detainees in highly restrictive conditions until the FBI cleared them. It alleged that they “knew of, condoned, and willfully and maliciously agreed to subject” him to harsh conditions solely for those reasons. It called Ashcroft the policy's “principal architect” and Mueller “instrumental” in adopting it.

Issues

1. Did the Court of Appeals have jurisdiction to review, before final judgment, a district court order that rejected qualified immunity by denying a motion to dismiss for insufficient pleading?
2. Does the pleading standard announced in Twombly govern all civil actions in the federal district courts, including a discrimination suit against federal officials, rather than only antitrust cases?
3. Did Iqbal's complaint plead enough factual matter, accepted as true, to state a plausible claim that Ashcroft and Mueller adopted the detention policy for the purpose of discriminating because of race, religion, or national origin?

Holding

The Court of Appeals had jurisdiction over the appeal, and Twombly's standard applies to all civil actions in the federal district courts. Iqbal's complaint did not plead sufficient facts to state a claim that Ashcroft and Mueller purposefully adopted a policy of classifying detainees as of high interest because of race, religion, or national origin, so it failed Rule 8 as to them.