## Facts

- After the September 11, 2001 attacks, federal authorities detained many noncitizens during the terrorism investigation.
- Javaid Iqbal, a Pakistani Muslim, was arrested on federal charges and designated a “person of high interest.”
- Iqbal was confined in highly restrictive conditions at the Metropolitan Detention Center in Brooklyn, including extensive lockdown, constant light, frequent strip searches, and alleged abuse.
- Iqbal brought a Bivens action alleging that he was subjected to harsh treatment because of race, religion, or national origin, in violation of the First and Fifth Amendments.
- He sued, among others, former Attorney General John Ashcroft and FBI Director Robert Mueller, asserting they created, approved, and implemented the allegedly discriminatory detention policy.

## Issues

1. Whether an interlocutory appeal lies under the collateral-order doctrine from denial of a motion to dismiss asserting qualified immunity.
2. Whether Rule 8 requires factual allegations sufficient to state a plausible claim, and whether this plausibility standard applies to all civil actions.
3. Whether a Bivens claim may proceed against high-level officials based on supervisory status, or instead requires pleading each official’s own unconstitutional conduct.

## Decision

- The Court held it had jurisdiction because denial of qualified immunity at the pleading stage is immediately appealable when it turns on an issue of law.
- The Court held the Twombly plausibility standard applies to all civil cases.
- The Court ruled the complaint failed to state a plausible claim that Ashcroft and Mueller themselves acted with unconstitutional discriminatory purpose.
- The Court rejected liability based on supervisory status; each defendant must be alleged to have violated the Constitution through his own actions.
- The Court reversed and remanded, leaving the lower court to consider whether amendment should be permitted.

## Legal Principles

- A complaint must plead enough nonconclusory factual matter to state a claim that is plausible on its face; labels and formulaic recitations are insufficient.
- Courts evaluating a Rule 12(b)(6) motion (1) disregard conclusory allegations not entitled to an assumption of truth, then (2) determine whether the remaining factual allegations plausibly support liability.
- Facts that are consistent with liability, but equally consistent with lawful conduct, do not alone satisfy plausibility.
- In Bivens actions, there is no respondeat superior liability; a plaintiff must plead and ultimately prove that each government official, through the official’s own individual actions, violated the Constitution.
- A supervisor’s position or generalized knowledge of subordinates’ conduct, without well-pleaded facts showing the supervisor’s own unconstitutional intent and conduct, does not state a claim.

## Conclusion

The Court required federal civil complaints to allege sufficient nonconclusory facts to plausibly show entitlement to relief, and it held that high-level officials cannot be held liable in a Bivens action based on supervisory role alone absent plausible allegations of their own unconstitutional conduct and intent.


Ashcroft v. Iqbal, 556 U.S. 662 (2009)