Conley v. Gibson, 355 U.S. 41 (1957)

Conley v. Gibson, 355 U.S. 41 (1957)

FACTS: Railroad companies in Texas and New Orleans (“Railroads”) terminated several of its African American employees. Although the Railroads claimed the action it took was due to retrenchment, it hired Caucasians to fill the vacant positions. The Railroads further demoted African Americans in senior positions and, rehired them in lower positions.

PROCEDURAL HISTORY: The African American employees (Petitioners) sued the Brotherhood of Railway and Steamship Clerks (Respondents) for discrimination. Respondents filed a motion to dismiss the complaint for failure to state a claim for which could be granted. The District Court granted Respondent’s motion. The Fifth Circuit affirmed the decision. SCOTUS granted certiorari.

JUDGMENT: Reversed and remanded.

ISSUE: Whether the Federal Rules requires one to detail the facts upon which they base their claim.

HOLDING OF THE COURT: The Federal Rules only require a plaintiff to give ‘a short and plain statement of the claim, which gives the defendant fair notice and grounds for those claims.

RATIONALE: The Court examined Rule 8(f), which states ‘all pleadings shall be so construed as to do substantial justice.’ In the Court’s view, not only did the Petitioners’ complaint have a short statement, but it also gave the Respondents fair notice. The Court also reasoned that pleadings are not a ‘game of skill,’ and that mistakes in pleadings cannot determine the merits of a case.

Quianna Canada

Quianna Canada

Quianna Canada is a B.A. Law student at the University of Arizona and a human rights defender. Her conversance with the American criminal justice system has made her passionate about justice and equality. Her focused researched on the ills of rankism, racism, and gender-based prejudice makes her an insightful expert at identifying maltreatment immanent in institutions, and how oppression effects ostracised persons in the world.

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