Conley v. Gibson

Conley v. Gibson, 355 U.S. 41 (1957), was a case decided by the Supreme Court of the United States that provided a basis for a broad reading of the "short plain statement" requirement for pleading under Rule 8 of the Federal Rules of Civil Procedure.[1]

Conley v. Gibson
Argued October 21, 1957
Decided November 18, 1957
Full case nameConley v. Gibson
Citations355 U.S. 41 (more)
78 S. Ct. 99; 2 L. Ed. 2d 80; 9 Fair Empl. Prac. Cas. (BNA) 439; 33 Lab. Cas. (CCH) ¶ 71,077; 1 Empl. Prac. Dec. (CCH) ¶ 9656; 41 L.R.R.M. 2089
Case history
Prior229 F.2d 436 (reversed)
Holding
General allegations of discrimination were sufficient to fulfill the Rule 8 requirement of a "short plain statement."
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Harold H. Burton
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Charles E. Whittaker
Case opinion
MajorityBlack, joined by unanimous
Laws applied
Railway Labor Act; Federal Rules of Civil Procedure
Overruled by
Bell Atlantic Corp. v. Twombly, 2007

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 to gain much more specificity before trial. The kind of pleading allowed by Conley was known as "notice pleading."[2]

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, 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 in 2009.

See also

References
  1. Yeazell, S.C. Civil Procedure, Seventh Edition. Aspen Publishers, New York, NY: 2008, p. 358
  2. Yeazell, p. 358
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