Ashcroft v. Iqbal

Javaid Iqbal (plaintiff) was detained in maximum security during the investigations following the September 11, 2001, terrorist attacks. Iqbal sued former United States attorney general John Ashcroft, Federal Bureau of Investigation (FBI) Director Robert Mueller, and other officials (defendants), claiming his conditions of confinement were unconstitutional. As against Ashcroft and Mueller, the complaint alleged that (1) the FBI, at Mueller’s direction, detained thousands of Arab Muslim men; (2) Ashcroft and Mueller agreed to a policy of holding such men under highly restrictive conditions until cleared by the FBI; and (3) Ashcroft and Mueller both willfully agreed to a policy that subjected Iqbal to harsh confinement conditions because of his religion, race, or national origin. Ashcroft and Mueller claimed qualified immunity and moved to dismiss Iqbal’s complaint for failure to state a claim. The district court denied the motion. While an interlocutory appeal was pending before the Second Circuit, the United States Supreme Court decided Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), in which it addressed Federal Rule of Civil Procedure (FRCP) 8’s pleading standard within the context of an antitrust case. The Second Circuit concluded that Twombly did not apply to Iqbal’s complaint because it asserted a straightforward discrimination claim, not a complex claim like that in Twombly. The Second Circuit affirmed the district court’s decision, concluding that Iqbal’s complaint sufficiently stated a claim against Ashcroft and Mueller. The United States Supreme Court granted certiorari.