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.
[2] 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.
[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.
[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.
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.
[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.
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.
The Supreme Court held that Iqbal's complaint failed to plead sufficient facts to state a claim for purposeful and unlawful discrimination.
To do so, the Court found, [w]here the claim is invidious discrimination in contravention of the First and Fifth Amendments, our decisions make clear the plaintiff must plead and prove that the defendant acted with discriminatory purpose.
It follows that, to state a claim based on a violation of a clearly established right, respondent must plead sufficient factual matter to show that petitioners adopted and implemented the detention policies at issue not for a neutral, investigative reason but for the purpose of discriminating on account of race, religion, or national origin.The Court rejected Iqbal's argument that under a theory of "supervisory liability," Ashcroft and Mueller could be liable for "knowledge and acquiescence in their subordinates' use of discriminatory criteria to make classification decisions among detainees.
"[20] Under Federal Rule of Civil Procedure 8(a)(2), a complaint must contain a "short and plain statement of the claim showing that the pleader is entitled to relief.... detailed factual allegations" are not required.
A claim has facial plausibility when the pleaded factual content allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.
Even if the complaint's well-pleaded facts gave rise to a plausible inference that Iqbal's arrest was the result of unconstitutional discrimination, that inference alone did not entitle him to relief since his claims rested solely on their ostensible policy of holding detainees categorized as "of high interest," but the complaint does not contain facts plausibly showing that their policy was based on discriminatory factors.
Firstly, the Court found that Iqbal's claim that Twombly should be limited to its antitrust context was not supported by that case or the Federal Rules.
"[23] The decision, referenced with predecessor opinion Bell Atlantic Corp. v. Twombly as "Twiqbal," has been described as possibly "the most consequential ruling in Chief Justice John G. Roberts Jr.'s 10-year tenure" because it has "transformed civil litigation in the federal courts" to the detriment of individuals.