Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit,
507 U.S. 163 (1993)

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No. 91-1657. Argued January 12, 1993-Decided March 3,1993

Petitioner homeowners filed suit under 42 U. S. C. § 1983 against respondents-local officials acting in their official capacity, a county, and two municipal corporations-alleging that the conduct of local police officers in searching their homes for narcotics violated the Fourth Amendment, and asserting that the basis for municipal liability was the failure adequately to train the police officers involved. The Federal District Court dismissed the complaints because they failed to meet the "heightened pleading standard" adopted by the Court of Appeals, which requires that complaints against municipal corporations in § 1983 cases state with factual detail and particularity the basis for the claim. The Court of Appeals affirmed.

Held: A federal court may not apply a "heightened pleading standard"more stringent than the usual pleading requirements of Federal Rule of Civil Procedure 8(a)-in civil rights cases alleging municipal liability under § 1983. First, the heightened standard cannot be justified on the ground that a more relaxed pleading standard would eviscerate municipalities' immunity from suit by subjecting them to expensive and timeconsuming discovery in every § 1983 case. Municipalities, although free from respondeat superior liability under § 1983, see Monell v. New York City Dept. of Social Services, 436 U. S. 658, do not enjoy absolute or qualified immunity from § 1983 suits, id., at 701; Owen v. City of Independence, 445 U. S. 622, 650. Second, it is not possible to square the heightened standard applied in this case with the liberal system of "notice pleading" set up by the Federal Rules. Rule 8(a)(2) requires that a complaint include only "a short and plain statement of the claim showing that the pleader is entitled to relief." And while Rule 9(b) requires greater particularity in pleading certain actions, it does not include among the enumerated actions any reference to complaints alleging municipal liability under § 1983. Pp. 165-169.

954 F.2d 1054, reversed and remanded.

REHNQUIST, C. J., delivered the opinion for a unanimous Court.


Richard Gladden argued the cause pro hac vice for petitioners. With him on the briefs was Don Gladden.

Brett A. Ringle argued the cause for respondents. With him on the brief for respondents Tarrant County Narcotics Intelligence and Coordination Unit et al. was Dixon W Holman. Kevin J. Keith filed a brief for respondent City of Grapevine, Texas, and Tim G. Sralla and Wayne K. Olson filed a brief for respondent City of Lake Worth, Texas. *

CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.

We granted certiorari to decide whether a federal court may apply a "heightened pleading standard" -more stringent than the usual pleading requirements of Rule 8(a) of the Federal Rules of Civil Procedure-in civil rights cases alleging municipal liability under Rev. Stat. § 1979, 42 U. S. C. § 1983. We hold it may not.

We review here a decision granting a motion to dismiss, and therefore must accept as true all the factual allegations in the complaint. See United States v. Gaubert, 499 U. S. 315, 327 (1991). This action arose out of two separate incidents involving the execution of search warrants by local law

*Briefs of amici curiae urging affirmance were filed for the State of Texas et al. by Dan Morales, Attorney General, Will Pryor, First Assistant Attorney General, Mary F. Keller, Deputy Attorney General, Adrian L. Young, Michael P. Hodge, Sharon Felfe, and Ann Kraatz, Assistant Attorneys General, and for the Attorneys General for their respective States as follows: Jimmy Evans of Alabama, Charles E. Cole of Alaska, Winston Bryant of Arkansas, Daniel E. Lungren of California, Robert A. Marks of Hawaii, Robert T. Stephan of Kansas, Nicholas J. Spaeth of North Dakota, Ernest D. Preate, Jr., of Pennsylvania, James E. O'Neil of Rhode Island, T. Travis Medlock of South Carolina, Mark Barnett of South Dakota, Paul Van Dam of Utah, Jeffrey L. Amestoy of Vermont, Mary Sue Terry of Virginia, Mario J. Palumbo of West Virginia, James E. Doyle of Wisconsin, and Joseph B. Meyer of Wyoming; for the City of College Station, Texas, by Catherine Locke; for the National Institute of Municipal Law Officers et al. by Richard Ruda; and for the Texas Municipal League et al. by Susan M. Horton.

Full Text of Opinion

Primary Holding

A court cannot impose a higher standard of pleading for a certain claim than what the Rules of Civil Procedure generally provide.

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