The United States Supreme Court's decision in Ashcroft v. Iqbal is the Court's awaited clarification of its earlier decision in Bell Atlantic Corp. v. Twombly. In the wake of Twombly, courts and commentators debated its application to cases other than antitrust disputes. The Court announced in Iqbal that the Twombly complaint requirement of facial plausibility applies to all civil actions filed in federal court, not just antitrust cases. Accordingly, Iqbal currently governs the standards by which all plaintiffs in federal court must draft complaints to state a legally sufficient claim for relief and survive a defendant's motion to dismiss. Survival will be tougher because this case confirms the end of the liberal pleading standards developed in Conley v. Gibson and its progeny.
Flake, Cassidy M.
"Ashcroft in a Defendant's Wonderland: Redefined Pleading Standards in Ashcroft v. Iqbal,"
Mercer Law Review: Vol. 61:
3, Article 12.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol61/iss3/12