Johnson v. City of Shelby, 135 S. Ct. 346

Background

Petitioners were police officers in Shelby, Mississippi who allege they were terminated by the board of aldermen after exposing criminal conduct by an alderman.
They sued the city seeking damages for violations of their Fourteenth Amendment due process rights.
The District Court entered summary judgment against petitioners for failing to invoke 42 U.S.C. § 1983 in their complaint.
The Fifth Circuit affirmed, requiring an express citation to § 1983 in the complaint.
The Supreme Court granted certiorari and summarily reversed, holding that Rule 8(a)(2) pleading standards do not require pleading the specific statute § 1983 by name.
The Court remanded and instructed that petitioners be allowed to amend to add a § 1983 citation if desired.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a complaint must expressly invoke 42 U.S.C. § 1983 to state a damages claim for constitutional violations	The complaint’s short, plain statement alleging city-caused constitutional deprivations suffices without citing § 1983	The City (and Fifth Circuit) argued plaintiffs must expressly plead § 1983 because it has consequences (e.g., respondeat superior limits) and affects defenses	Court held that Rule 8(a)(2) does not require expressly pleading § 1983; dismissal for failure to cite the statute was improper
Whether Twombly/Iqbal heightened factual pleading governs here	Petitioners: factual allegations were sufficient to state a plausible claim	City: argued pleading deficiencies justified dismissal under Twombly/Iqbal principles	Court: Twombly/Iqbal concern factual sufficiency; petitioners’ factual allegations were adequate under Rule 8
Whether heightened pleading is permitted in civil-rights/municipal-liability suits	Petitioners: no special heightened pleading requirement applies	City/Fifth Circuit: applied a stricter rule requiring citation to § 1983	Court: rejected heightened pleading for the formality of citing § 1983; Leatherman bars stricter standards in municipal liability suits
Whether qualified immunity analysis was implicated by failure to plead § 1983	Petitioners: suit was only against the municipality, so qualified immunity for officers is irrelevant	City: suggested § 1983 label affects qualified immunity considerations	Court: qualified immunity not implicated because no individual officers were sued; municipal defendant cannot assert officers’ good faith as defense

Key Cases Cited

Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit, 507 U.S. 163 (prohibiting heightened pleading standards in municipal liability civil-rights cases)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (rejecting heightened pleading in employment discrimination suits; Rule 8(a)(2) governs)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (establishing plausibility standard for factual allegations)
Ashcroft v. Iqbal, 556 U.S. 662 (applying plausibility pleading standard to constitutional claims)
Owen v. City of Independence, 445 U.S. 622 (municipality cannot assert officers’ good-faith as a defense to § 1983 liability)