Garcia-Catalan v. United States, 734 F.3d 100

Background

Plaintiff Itzel García-Catalán alleged she slipped on liquid in a Fort Buchanan commissary on June 24, 2009, injuring herself; no wet-floor sign was present.
She filed an administrative FTCA claim; after the agency failed to act within the statutory period, she sued the United States in federal district court under Puerto Rico law.
The government moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing plaintiff failed to plead actual or constructive knowledge of the dangerous condition.
A magistrate judge recommended denying the motion; the district court sua sponte rejected that recommendation, granted the motion, and dismissed with prejudice.
The First Circuit reviewed de novo whether the complaint plausibly alleged the knowledge element required under Puerto Rico premises-liability law and whether the pleading met the Iqbal/Twombly plausibility standard.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of pleading under Twombly/Iqbal (Rule 12(b)(6))	Complaint (Form-based) disclosed date, place, condition, and injury; facts suffice to make claim plausible and give fair notice	Allegations fail to plead actual or constructive knowledge required by Puerto Rico law	Reversed: whole-complaint reading makes a plausible inference of knowledge; dismissal improper
Element: actual or constructive knowledge of dangerous condition	Facts that a dangerous condition existed in a public area controlled by defendant and no warning sign supports reasonable inference of knowledge	Requires more specific factual allegations showing defendant knew or should have known (per district court)	Held pleadings need not meet trial or summary-judgment proof; plausible inference can arise from circumstantial allegations
Applicability of pre-Iqbal forms (Form 11) after Twombly/Iqbal	Form-based complaints can satisfy plausibility if they include sufficient factual detail	Forms are insufficient if they merely recite elements without factual content	Court held forms remain viable when they contain enough facts to make a claim plausible; Rule 84 supports use of forms
Need for discovery to fill factual gaps	Key facts (how long liquid was present, employee awareness) likely within defendant's control; discovery may reveal evidence	Plaintiff should have alleged more before discovery	Court recognized that discovery can reasonably be expected to fill holes and that some latitude is appropriate where defendant controls information

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard requires factual plausibility beyond sheer possibility)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility and reasonable expectation that discovery will reveal evidence)
Conley v. Gibson, 355 U.S. 41 (historic pleading standard discussed and contrasted)
Mas v. United States, 984 F.2d 527 (trial-stage failure of proof of defendant's knowledge; distinguished from pleading-stage review)
Nieves-Romero v. United States, 715 F.3d 375 (summary-judgment grant for lack of evidence of knowledge; distinguished from pleading-stage)
Rodríguez-Reyes v. Molina-Rodríguez, 711 F.3d 49 (two-step Iqbal/Twombly pleading analysis; factual vs. conclusory allegations)
Grajales v. P.R. Ports Auth., 682 F.3d 40 (plaintiff need not plead high factual specificity; circumstantial allegations may suffice)
Menard v. CSX Transp., Inc., 698 F.3d 40 (latitude in plausibility standard where defendant controls key information)
K-Tech Telecomm., Inc. v. Time Warner Cable, Inc., 714 F.3d 1277 (federal forms remain viable post-Twombly/Iqbal when factual allegations suffice)
Hamilton v. Palm, 621 F.3d 816 (same point on federal forms' viability)
Leatherman v. Tarrant Cnty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163 (courts cannot amend civil rules by interpretation)
Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (pleading must provide fair notice and be facially plausible)