Jones v. United States Postal Service
690 F. App'x 147
| 5th Cir. | 2017Background
- Jones sued USPS (and later added the U.S. Attorney General and U.S. Attorney’s Office) alleging a variety of wrongs but filed pleadings lacking coherent factual allegations.
- Original complaint listed an assortment of statutes, constitutional provisions, and rules without factual context or a clear legal theory.
- Amended complaint attached a December 2014 USPS notice that its systems were hacked and Jones’s personal data may have been compromised; also attached an EEOC dismissal of a related 2015 complaint.
- Amended pleading used an employment-discrimination form but contained no factual narrative tying alleged race/gender discrimination or failure to promote to any actionable conduct; requested $500 billion.
- A separate pleading asserted breach of contract/tortious-interference elements without identifying any contract, dates, or factual basis; requested varied non-monetary relief.
- District court dismissed under Fed. R. Civ. P. 12(b)(6) for failure to state a claim and denied default judgment (USPS was not served). Appeal followed; judgment affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleadings under Rule 8(a) / failure to state a claim | Jones alleged legal authorities and listed purported harms (discrimination, perjury, whistleblower retaliation) and attachments show USPS data breach; claims should proceed. | USPS argued pleadings are conclusory, lack factual allegations, and do not plead a plausible claim as required by Twombly/Iqbal. | Court held pleadings insufficient under Rule 8 and Twombly/Iqbal; dismissal for failure to state a claim affirmed. |
| Plausibility requirement / ability to draw reasonable inferences | Jones contends cited statutes and attachments provide enough notice. | Defendant contends there are only naked assertions and no factual content to allow reasonable inference of liability. | Court held Jones’s filings lacked factual content to permit reasonable inferences; claims not facially plausible. |
| Service/default judgment request | Jones sought default judgment based on USPS absence. | USPS/nonmoving party noted it was never served; absence not properly attributable to defendant. | Court held default judgment improper where defendant was not served; district court rightly denied it. |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must allege enough facts to state a claim that is plausible on its face)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (conclusory allegations and threadbare recitals insufficient to make claims plausible)
- Lone Star Fund V (U.S.), L.P. v. Barclays Banks PLC, 594 F.3d 383 (5th Cir. 2010) (assessing plausibility standard in this circuit)
- Conley v. Gibson, 355 U.S. 41 (U.S. 1957) (historical articulation of notice-pleading standard referenced by Twombly)
