## Facts

- A state prisoner filed a pro se 42 U.S.C. § 1983 action against New York correctional officials alleging he was transferred to North Carolina authorities while a New York state habeas corpus challenge to extradition was pending.
- The complaint set out specific factual allegations (including names and dates) and attached supporting documents, including detainer and extradition materials.
- The court had granted in forma pauperis status and previously noted the allegations stated tenable constitutional claims.
- After service, defense counsel sought and obtained an extension to answer, citing the need to gather information concerning a purportedly related federal action.
- Defendants then filed a brief, standardized “form answer” that functioned as a blanket denial and did not respond to the complaint’s specific, document-supported allegations.
- The court, on its own initiative, examined whether the answer complied with Federal Rules of Civil Procedure 8(b) and 11.

## Issues

1. Whether a generalized “form answer” that essentially denies all allegations satisfies Rule 8(b) when the complaint contains specific allegations supported by exhibits.
2. Whether filing such a boilerplate denial after obtaining time to investigate violates Rule 11’s requirement that counsel have good ground for the pleading and that it not be interposed for delay.

## Decision

- The court held the defendants’ generalized form answer did not comply with Rule 8(b) and was inconsistent with Rule 11’s certification requirements.
- The court struck the answer.
- The court allowed defendants 20 days to file a new answer that met the requirements of Rules 8(b) and 11.
- The court did not decide the merits of the underlying § 1983 claims.

## Legal Principles

- Rule 8(b) permits defenses stated in short and plain terms, but denials ordinarily must be directed to designated allegations; a general denial is acceptable only when made in good faith.
- Rule 11 (as then in effect) required an attorney’s signature to certify that counsel read the pleading, had good ground to support it, and did not file it for delay; a sham or false pleading could be stricken and counsel could face discipline for willful violations.
- When a complaint is detailed and supported by documents, a boilerplate general denial may fail to give adequate notice of what is genuinely disputed and may indicate a lack of reasonable inquiry.

## Conclusion

The court enforced Rules 8(b) and 11 by striking a stock general denial that did not meaningfully answer a detailed, exhibit-supported complaint, while permitting defendants to cure the defect by filing a compliant amended answer within 20 days.


White v. Smith, 91 F.R.D. 607 (W.D.N.Y. 1981)