Ashcroft v. Iqbal

556 U.S. 662 (2009)

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Nature of the Case

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Facts

Iqbal (P) is a citizen of Pakistan and a Muslim. After 9-11, the FBI questioned more than 1,000 people with suspected links to the attacks. Some 762 were held on immigration charges, and a 184-member subset of that group was deemed to be “of ‘high interest’” to the investigation. The high-interest detainees were held under restrictive conditions designed to prevent them from communicating with the general prison population or the outside world. P was one of the detainees. The FBI and INS arrested him on charges of fraud in relation to identification documents and conspiracy to defraud the United States. Pending trial, P was housed at the Metropolitan Detention Center (MDC) in Brooklyn, New York. P was placed in a section of the MDC known as the Administrative Maximum Special Housing Unit. P was kept in lockdown 23 hours a day, spending the remaining hour outside his cell in handcuffs and leg irons accompanied by a four-officer escort. P pleaded guilty, served a prison term and was removed to Pakistan. P then filed a Bivens action against 34 plus individuals. P alleges that the jailors “kicked him in the stomach, punched him in the face, and dragged him across” his cell without justification; subjected him to serial strip and body-cavity searches when he posed no safety risk to himself or others; and refused to let him and other Muslims pray because there would be “no prayers for terrorists.” P alleges that Ds designated P a person of high interest on account of his race, religion, or national origin, in contravention of the First and Fifth Amendment s to the Constitution. P alleged 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.” That “the 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.” 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.” Ds moved to dismiss the complaint for failure to state sufficient allegations to show their own involvement in clearly established unconstitutional conduct. The District Court denied their motion. The Court of Appeals considered Twombly’s applicability to the case. It concluded that Twombly called for a “flexible ‘plausibility standard,’ which obliges a pleader to amplify a claim with some factual allegations in those contexts where such amplification is needed to render the claim plausible.” The court found that D's appeal did not present one of “those contexts” requiring amplification. As a consequence, it held P’s pleading adequate to allege Ds' personal involvement in discriminatory decisions which, if true, violated clearly established constitutional law.