Ashcroft v. Iqbal

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2009 United States Supreme Court case

Ashcroft v. Iqbal, 556 U.S. 662 (2009), is a landmark decision of the Supreme Court of the United States that held that a plaintiff in a civil law case must plead a claim in a "plausible" manner. Alongside _Bell Atlantic Corp. v. Twombly _ (together known as Twiqbal ), Iqbal raised the threshold which plaintiffs need to meet to commence a lawsuit. Further, the Court held that government officials are not liable for the actions of their subordinates without evidence that they ordered the allegedly discriminatory activity. At issue was whether current and former federal officials, including FBI Director Robert Mueller and former United States Attorney General John Ashcroft , were entitled to qualified immunity against an allegation that they knew of or condoned racial and religious discrimination against Muslim men detained after the September 11 attacks .[1] The decision also "transformed civil litigation in the federal courts" by making it significantly easier for courts to dismiss individuals' suits.[2]

Background

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On the morning of September 11, 2001, Javaid Iqbal, a Pakistani-American cable television installer, was in lower Manhattan when the World Trade Center was attacked. He had been on his way to renew his work authorization card, as he was an immigrant and did not yet have permanent citizenship.[3] In an initially unrelated action eight weeks later, he was arrested on charges of conspiracy to defraud the United States and fraud in relation to identification documents (violations of 18 U.S.C. §§ 371 and 1028), and he was placed in pretrial detention at the Metropolitan Detention Center in Brooklyn , New York .[4] When officers searched his apartment, they found a card for an appointment to be downtown on 9/11, as well as media reporting on the attacks, and suspected him of involvement.[3]

Iqbal alleged that FBI officials carried out a discriminatory policy by designating him as a person "of high interest" in the investigation of the September 11 attacks because of his race, religion, and national origin. He asserted that it was because of his identity as a Pakistani Muslim that he was placed in the detention center's Administrative Maximum Special Housing Unit for over six months while he was awaiting the fraud trial.

Iqbal asserted that he was tortured by prison staff on the orders of, and under policies written by, John Ashcroft. Specifically, he claimed that on the day he was transferred to the special unit, prison guards , without provocation, "picked him up and threw him against the wall, kicked him in the stomach, punched him in the face, and dragged him across the room."[5] He testified that after being attacked a second time, he sought medical attention but was denied care for two weeks.[6] Further, Iqbal asserted that prison staff in the special unit subjected him to unjustified strip and body cavity searches,[7] verbally berated him by calling him a "terrorist " and "Muslim killer,"[8] refused to give him adequate food,[9] subjected him to extreme heat and cold,[10] Further, he stated that prison staff interfered with his attempts at prayer , to engage in religious study,[11] and his access to counsel .[12]

Iqbal pleaded guilty to using another man's Social Security card on April 22, 2002, and was sentenced to prison, where he remained until his release on January 15, 2003. While in prison, his wife divorced him, thus invalidating his green card . Iqbal was deported to Pakistan after his release.[3] [13] [14] Upon his return to Pakistan he was branded an American agent. His son was persecuted and forcibly disappeared as a result.[3]

The Metropolitan Detention Center in Brooklyn , New York where Mr. Iqbal was allegedly abused.

After being released, Iqbal brought claims under implied causes of action established by _Bivens v. Six Unknown Named Agents _ for violations of his First , Fourth , Fifth , Sixth , and Eighth Amendment rights as well as various statutory claims, including Federal Tort Claims Act claims against the United States seeking compensatory and punitive damages . Iqbal argued that Mueller and Ashcroft personally condoned the decision to detain him as well as Arab immigrants to the US .

The Office of Inspector General of the Department of Justice had previously investigated and confirmed accounts of abuse of September 11 detainees like Iqbal.[15] The OIG conducted more than one hundred interviews and obtained videotape evidence in its investigation of conditions at the MDC.[16]

The federal government argued that Iqbal's legal filings were not specific enough in linking the government officials with a policy of detaining Arab immigrants and Muslims.[17] The District Court found that the facts alleged in Iqbal's complaint were sufficient. It also found that the OIG Report suggested that petitioners were personally involved in "creating or implementing" the policies that led to respondent's confinement in the Administrative Maximum Special Housing Unit.[18] The United States Court of Appeals for the Second Circuit affirmed the lower court and refused to dismiss the action, concluding that it was plausible enough to survive a Rule 12(b)(6) motion to dismiss.[_citation needed
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The Supreme Court granted review, in part, to address "whether conclusory allegations that high-level government officials had knowledge of alleged wrongdoing by subordinate officials are sufficient to survive a motion to dismiss in an action brought under _Bivens ."[citation needed
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Decision

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In a 5–4 decision, delivered on May 18, 2009, by Justice Kennedy , the Supreme Court reversed the Second Circuit's decision that the plaintiff had pleaded sufficient facts. The Supreme Court held that Iqbal's complaint failed to plead sufficient facts to state a claim for purposeful and unlawful discrimination. The court affirmed that the Second Circuit had subject matter jurisdiction to affirm the District Court's order denying petitioners' motion to dismiss.

Supervisory liability

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