Conley v. Gibson

Conley v. Gibson, 355 U.S. 41 (1957), was a case decided by the Supreme Court of the United States that provided a basis for a broad reading of the "short and plain statement" requirement for pleading under Rule 8 of the Federal Rules of Civil Procedure.

[1] The case arose from an alleged wrongful discharge of African-American employees from a railroad company and unequal protection from the union.

In 2007, the United States Supreme Court overruled Conley, creating a new, stricter standard of a pleading's required specificity.

Under the standard the Court set forth in Conley, a complaint need only state facts which make it "conceivable" that it could prove its legal claims—that is, that a court could only dismiss a claim if it appeared, beyond a doubt, that the plaintiff would be able to prove "no set of facts" in support of her claim that would entitle her to relief.

In Bell Atlantic Corp. v. Twombly, the court adopted a more strict, "plausibility" standard, requiring in this case "enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of illegal agreement."