Leatherman v. Tarrant County – Case Brief Summary
Summary of Leatherman v. Tarrant County, 507 U.S. 163 (1993).
Facts
Two plaintiffs brought actions against defendant Tarrant County (D) for violations of their civil rights under 42 USC § 1983 stemming from allegedly improper searches of their homes. One plaintiff alleged that the officers had assaulted him and the other plaintiff alleged that officers had killed her dogs during a search conducted in her absence.
Procedural History
Case law in the Fifth Circuit had established a heightened pleading standard for cases brought against municipalities under 42 USC 1983. The district court dismissed the plaintiffs’ complaint for failure to meet the heightened pleading standard established by Fifth Circuit case law. The Court of Appeals affirmed and the Supreme Court granted certiorari.
Issue
Can a court adopt special heightened standards of pleading for certain categories of cases?
Holding and Rule
No. A court cannot adopt special heightened pleading standards for certain categories of cases.
The Federal Rules of Civil Procedure follow the notice pleading standard. Under FRCP 8(a)(2) the complaint need only put the court and the defendant on notice of the causes of action. The complaint must state factual details and the basis for the claim. For proper notice, a complaint need only present a short and plain statement of the claim showing that the pleader is entitled to relief.
FRCP 9(b) imposes a particularity requirement only for averments of fraud or mistake and cannot be extended to other types of cases (“expressio unius est exclusio alterius” – the mention of some implies the absence of others not mentioned).
Disposition
Reversed and remanded.
See Edmonson v. Leesville Concrete Co., Inc. for a law school civil procedure case brief involving a peremptory challenge issue in the context of a civil rights case.