## Facts

- Former police officers in Shelby, Mississippi alleged they were terminated after exposing alleged criminal conduct by a city alderman.
- The officers claimed the stated reason for their termination—violations of police procedures and residents’ rights—was pretextual.
- They sought compensatory damages from the City, alleging violations of Fourteenth Amendment due process rights.
- The complaint alleged constitutional violations but did not expressly cite 42 U.S.C. § 1983.

## Issues

1. Whether a complaint seeking damages for alleged constitutional violations against a municipality may be dismissed solely because it fails to expressly invoke 42 U.S.C. § 1983.
2. Whether Federal Rule of Civil Procedure 8(a)(2) permits dismissal for an imperfect statement of the legal theory when the factual allegations give fair notice and plausibly support relief.

## Decision

- The district court entered summary judgment for the City based on the officers’ failure to invoke § 1983 and denied leave to amend.
- The Fifth Circuit affirmed, treating express invocation of § 1983 as necessary for notice due to doctrinal consequences associated with § 1983 litigation.
- The Supreme Court summarily reversed in a per curiam decision.
- The Court held that federal pleading rules do not permit dismissal merely because plaintiffs failed to cite § 1983 when the complaint otherwise alleged facts supporting a constitutional claim for relief.
- The Court noted qualified immunity analysis was not implicated because the officers sued only the City, not individual officials.

## Legal Principles

- Rule 8(a)(2) requires a “short and plain statement” showing entitlement to relief; it does not require a complete or perfectly labeled legal theory.
- Federal courts may not impose a heightened pleading requirement on civil-rights claims alleging municipal liability beyond Rule 8(a)’s standard.
- A complaint may proceed when it provides fair notice of the factual basis of the claim and plausibly alleges entitlement to relief, even if it omits the statutory label commonly used to enforce the constitutional right.
- Qualified immunity is a defense for individual officials, not municipalities; municipalities cannot invoke officers’ good faith as a defense to § 1983 liability.

## Conclusion

The Supreme Court held that the Federal Rules’ notice-pleading standard does not require plaintiffs seeking damages for constitutional violations to expressly cite § 1983, and it reversed dismissal where the complaint’s factual allegations adequately stated a plausible constitutional claim against a municipality.


Johnson v. City of Shelby, 574 U.S. 10 (2014)