## Facts

- Karun N. Jackson and Ursula D. Jackson owned a residence in Baldwin County, Alabama that was sold at a foreclosure sale on January 11, 2016.
- On January 12, 2016, the Jacksons sued Bank of America, N.A.; Specialized Loan Servicing LLC; Bank of New York Mellon; and Mortgage Electronic Registration Systems, Inc., asserting numerous Alabama and federal claims arising from the foreclosure.
- Defendants removed the action to the U.S. District Court for the Southern District of Alabama.
- Defendants challenged the pleading as a “shotgun” complaint that was vague, conclusory, and failed to connect specific facts to specific claims and defendants.
- The district court ordered repleader and gave plaintiffs an opportunity to file an amended complaint complying with Rule 8’s “short and plain statement” requirement.
- Plaintiffs filed an amended complaint that remained incomprehensible and did not cure the identified defects.
- The district court dismissed the action with prejudice under Rule 12(b)(6) and denied further leave to amend.
- Plaintiffs appealed, defending the sufficiency of the amended complaint.

## Issues

1. Whether dismissal with prejudice was proper after plaintiffs were given an opportunity to amend a shotgun complaint but filed an amended pleading that remained incomprehensible and noncompliant with Rule 8.
2. Whether a district court may dismiss with prejudice, under its inherent authority to manage its docket, when litigants persist in prosecuting an abusive pleading that obstructs the due administration of justice.

## Decision

- The Eleventh Circuit affirmed the judgment.
- The court affirmed on an alternative ground: plaintiffs’ attempt to prosecute an incomprehensible shotgun pleading to judgment obstructed the due administration of justice.
- The court concluded that, after being ordered to replead and given an opportunity to cure, plaintiffs were not entitled to repeated chances to amend.
- The court ordered plaintiffs’ counsel to show cause why sanctions should not be imposed based on the abusive pleading and continued pursuit of the appeal.

## Legal Principles

- Rule 8(a)(2) requires a short and plain statement showing entitlement to relief; conclusory allegations and unclear pleading that prevents understanding of claims fails this standard.
- Under Twombly and Iqbal, a complaint must plead sufficient factual matter to state a plausible claim; “threadbare” recitals and conclusory statements are insufficient.
- “Shotgun pleadings” that lump allegations together, incorporate preceding paragraphs into multiple counts, and fail to specify which facts support which claims against which defendants are improper and must be policed by district courts.
- A district court has inherent authority to manage its docket and may dismiss with prejudice when a party persists, after a meaningful opportunity to amend, in filing an incomprehensible pleading that obstructs judicial administration.
- Once a plaintiff has been warned of pleading defects and given an opportunity to replead, denial of further leave to amend may be appropriate where the amended complaint does not cure the defects.

## Conclusion

The Eleventh Circuit upheld dismissal with prejudice because the plaintiffs, despite being directed to replead, continued to litigate an incomprehensible shotgun complaint that impeded the court’s ability to administer the case, warranting dismissal under the court’s inherent authority.


Jackson v. Bank of Am., N.A., 898 F.3d 1348 (11th Cir. 2018)