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Jones v. United States Postal Service
690 F. App'x 147
| 5th Cir. | 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Jones v. United States Postal Service
Court Name: Court of Appeals for the Fifth Circuit
Date Published: Apr 12, 2017
Citation: 690 F. App'x 147
Docket Number: 16-20789 Summary Calendar
Court Abbreviation: 5th Cir.