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Ashcroft v. Iqbal

Facts of the Case

Provided by Oyez

In the aftermath of September 11th, the FBI arrested thousands of Arab Muslim men as part of its investigation into the attacks. One of these men, Javaid Iqbal, was classified as being a "high interest" detainee at the Metropolitan Detention Center in Brooklyn, New York. Iqbal claims that during his detention he was segregated from the rest of the prison population and mistreated in several ways, including confinement to a cell for 23 hours a day where he had blinding light shone on him constantly and air conditioning pumped into the cell even during the winter months. After being released, Iqbal brought a suit against representatives of the Department of Justice, Bureau of Prisons, and FBI alleging 21 violations of his statutory and constitutional rights based on his treatment while confined. These defendants argued that they should be protected from the suit in their official governmental roles through qualified immunity. The United States District Court for the Eastern District of New York denied the defendants' motion to dismiss and rejected the qualified immunity defense.

The U.S. Court of Appeals for the Second Circuit affirmed the district court's rulings on all counts but one for violation of the right to due process. The Second Circuit noted that the actions taken by the government occurred in the immediate aftermath of September 11th and therefore created a unique context in which Iqbal's claims had to be reviewed. Even with these circumstances, however, the court felt that the qualified immunity defense could protect the government only from the due process claim. The "serious allegations of gross mistreatment" were enough to sustain the remaining counts.

Questions

  1. Are governmental officers acting in their official capacities protected by the defense of qualified immunity in a claim brought by a former prison inmate, arrested in the immediate aftermath of September 11, alleging gross treatment and violations of his constitutional rights while confined?

  2. Are conclusory allegations that high-ranking government officers knew of or condoned allegedly unconstitutional acts by subordinate officials sufficient to state a claim for unlawful discrimination?

Conclusions

  1. Not Answered and No. The Supreme Court held that the Second Circuit had jurisdiction to affirm the district court's order denying the defendants' motion to dismiss Mr. Iqbal's claim. However, the Court also held that Mr. Iqbal failed to plead sufficient facts to state a claim for unlawful discrimination. With Justice Anthony M. Kennedy writing for the majority and joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Clarence Thomas, and Samuel A. Alito, the Court reasoned that Mr. Iqbal needed to plead sufficient facts to show that the defendants implemented their policies for the purpose of discrimination. Mr. Iqbal did not do this and thus his complaint was deficient. The Court remanded the case for the district court to determine whether Mr. Iqbal may amend his complaint.

    Justice David H. Souter wrote a separate dissenting opinion and was joined by Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen G. Breyer. He disagreed with the majority's opinion that Mr. Iqbal failed to state a claim. Rather, he argued that since the defendants admitted that they would be liable if they knew their subordinates' conduct was deliberately discriminatory, that Mr. Iqbal did plead sufficient facts to state a claim for unlawful discrimination.