This is my first read of the majority opinion in Ashcroft v. Iqbal.
I believe that the Huffington Post and all conventional media (as usual) has overstated the significance of today's ruling.
First the relevant facts as described by the majority below the fold.
The allegations against petitioners are the only ones relevant here. The complaint contends that petitioners designated respondent a person of high interest on account of his race, religion, or national origin, in contravention of the First and Fifth Amendments to the Constitution. The complaint alleges that "the [FBI], under the direction of Defendant MUELLER, arrested and detained thousands of Arab Muslim men ... as part of its investigation of the events of September 11. It further alleges that "[t]he policy of holding post-September-11th detainees in highly restrictive conditions of confinement until they were ‘cleared’ by the FBI was approved by Defendants ASHCROFT and MUELLER in discussions in the weeks after September 11, 2001." Lastly, the complaint posits that petitioners "each knew of, condoned, and willfully and maliciously agreed to subject" respondent to harsh conditions of confinement "as a matter of policy, solely on account of [his] religion, race, and/or national origin and for no legitimate penological interest." The pleading names Ashcroft as the "principal architect" of the policy, and identifies Mueller as "instrumental in [its] adoption, promulgation, and implementation.".
The essential claim against Ashcroft and Mueller here is that they classified Iqbal as a "high interest" detainee only because of his race, in violation of his constitutional rights.
The court rejected the premise that this case was about detainee abuse as Iqbal had argued because Ashcroft and Mueller (the only named defendants) did not actually commit the abuse against Iqbal, and there was no indication that Iqbal would contend that they ordered it.
For the Majority then, the case turned on whether Iqbal plead with sufficient detail his allegation that he was targeted because of his race as a result of the systematic policies put forth by Ashcroft and Mueller.
First, a brief civil procedure lesson is required.
What is a pleading?
For the purposes of this case, think of the "pleading" as pre-trial documents which put forth what the parties intend to argue at trial. The pleading in question in this case, is Iqbal's original complaint against Ashcroft.
What is this sufficient detail jazz?
It used to be that a plaintiff could put down just a general allegation against a defendant, and that would be sufficient. However, in 2007, the court held in Bell Atlantic v. Twombley that this is no longer the case. So in some cases, where the court believes the plaintiff is just on a fishing expedition against the defendant, it will prevent hte case from moving forward by holding that the plaintiff did not complain sufficient facts.
To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to "state a claim to relief that is plausible on its face." A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. The plausibility standard is not akin to a "probability requirement," but it asks for more than a sheer possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are "merely consistent with" a defendant’s liability, it "stops short of the line between possibility and plausibility of ‘entitlement to relief.’ "
What does this mean?
Well to the plaintiff it means that they have to have their ducks in a row before they bring a case. In cases involving allegations of conspiracy, discimrimination etc. that are difficult to prove without having the benefit of discovery (a process after the pleading stage in which both sides have to disclose certain information and make certain witnesses available).
Moving back to the case at hand then
The court first holds that Iqbal's pleading was infufficient to allow him to continue on his theory that he was discriminated against because of his race by Ashcroft or Mueller.
But even if the complaint’s well-pleaded facts give rise to a plausible inference that respondent’s arrest was the result of unconstitutional discrimination, that inference alone would not entitle respondent to relief. It is important to recall that respondent’s complaint challenges neither the constitutionality of his arrest nor his initial detention in the MDC. Respondent’s constitutional claims against petitioners rest solely on their ostensible "policy of holding post-September-11th detainees" in the ADMAX SHU once they were categorized as "of high interest." To prevail on that theory, the complaint must contain facts plausibly showing that petitioners purposefully adopted a policy of classifying post-September-11 detainees as "of high interest" because of their race, religion, or national origin.
What does this mean?
I believe this sends a strong signal that, moving forward, the conservative majority on the court is going to be unwilling to allow cases against high level officials alleging some sort of illegal policy decision that is not plead with balls on certainty.
I look forward to input in the comments as I am merely a 1L and this is a first read of the Majority opinion only. It's possible I may find the ambition to highlight the other opinions later.