Definition[edit | edit source]
Failure to state a claim upon which relief can be granted is a defense to a legal claim. It means that the claimant has failed to present sufficient facts which, if taken as true, would indicate that a violation of law had occurred or that the claimant was entitled to a legal remedy.
Overview[edit | edit source]
In U.S. federal courts, the defense is set forth at Federal Rules of Civil Procedure, Rule 12(b)(6).
To defeat a motion to dismiss filed pursuant to Rule 12(b)(6), a plaintiff must plead "enough facts to state a claim to relief that is plausible on its face." A claim meets the "plausibility test"
|“||when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. The plausibility standard is not akin to a 'probability requirement,' but it asks for more than a sheer possibility that a defendant has acted unlawfully."||”|
While a complaint need not contain detailed factual allegations, it must set forth "more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." The “[f]actual allegations of [a complaint] must be enough to raise a right to relief above the speculative level . . . on the assumption that all the allegations in the complaint are true (even if doubtful in fact)." When the allegations of the pleading do not allow the court to infer more than the mere possibility of wrongdoing, they fall short of showing that the pleader is entitled to relief.
In reviewing a Rule 12(b)(6) motion, the court must accept all well-pleaded facts in the complaint as true and view them in the light most favorable to the plaintiff. In ruling on such a motion, the court cannot look beyond the pleadings. The pleadings include the complaint and any documents attached to it. Likewise, "'[d]ocuments that a defendant attaches to a motion to dismiss are considered part of the pleadings if they are referred to in the plaintiff's complaint and are central to [the plaintiff's] claims.'"
The ultimate question in a Rule 12(b)(6) motion is whether the complaint states a valid claim when it is viewed in the light most favorable to the plaintiff. While well-pleaded facts of a complaint are to be accepted as true, legal conclusions are not "entitled to the assumption of truth." Further, a court is not to strain to find inferences favorable to the plaintiff and is not to accept conclusory allegations, unwarranted deductions, or legal conclusions. The court does not evaluate the plaintiff's likelihood of success; instead, it only determines whether the plaintiff has pleaded a legally cognizable claim. Stated another way, when a court deals with a Rule 12(b)(6) motion, its task is to test the sufficiency of the allegations contained in the pleadings to determine whether they are adequate enough to state a claim upon which relief can be granted. Accordingly, denial of a 12(b)(6) motion has no bearing on whether a plaintiff ultimately establishes the necessary proof to prevail on a claim that withstands a 12(b)(6) challenge.
References[edit | edit source]
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (full-text); Reliable Consultants, Inc. v. Earle, 517 F.3d 738, 742 (5th Cir. 2008) (full-text); Guidry v. American Pub. Life Ins. Co., 512 F.3d 177, 180 (5th Cir. 2007) (full-text).
- Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (full-text) (internal citations omitted).
- Twombly, 550 U.S. at 555 (citation omitted).
- Id. (quotation marks, citations, and footnote omitted).
- Iqbal, 556 U.S. at 679.
- Sonnier v. State Farm Mutual Auto. Ins. Co., 509 F.3d 673, 675 (5th Cir. 2007) (full-text); Martin K. Eby Constr. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004) (full-text); Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996) (full-text).
- Id.; Spivey v. Robertson, 197 F.3d 772, 774 (5th Cir. 1999) (full-text), cert. denied, 530 U.S. 1229 (2000).
- Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498–99 (5th Cir. 2000) (full-text).
- Id. (quoting Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429, 431 (7th Cir. 1993)).
- Great Plains Trust Co. v. Morgan Stanley Dean Witter, 313 F.3d 305, 312 (5th Cir. 2002) (full-text).
- Iqbal, 556 U.S. at 679 (citation omitted).
- R2 Invs. LDC v. Phillips, 401 F.3d 638, 642 (5th Cir. 2005) (full-text) (citations omitted).
- United States ex rel. Riley v. St. Luke's Episcopal Hosp., 355 F.3d 370, 376 (5th Cir. 2004) (full-text).
- Mann v. Adams Realty Co., 556 F.2d 288, 293 (5th Cir. 1977) (full-text); Doe v. Hillsboro Indep. Sch. Dist., 81 F.3d 1395, 1401 (5th Cir. 1996) (full-text), rev'd on other grounds, 113 F.3d 1412 (5th Cir. 1997) (full-text) (en banc).
- Adams, 556 F.2d at 293.