Ashcroft v. Iqbal
| Ashcroft v. Iqbal | |
|---|---|
|
|
| Argued December 10, 2008 Decided May 18, 2009 |
|
| Full case name | John D. Ashcroft, former Attorney General, et al., Petitioners v. Javaid Iqbal, et al. |
| Docket nos. | 07-1015 |
| Citations | 556 U.S. 662 (more)
129 S.Ct. 1937
|
| Argument | Oral argument |
| Prior history | dismissal denied 2005 WL 2375202 (E.D.N.Y., 2005), upheld 490 F. 3d 143 (2nd. Cir.), Reversed and remanded U.S. |
| Holding | |
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Top government officials are not liable for the actions of their subordinates absent evidence that they ordered the allegedly discriminatory activity. |
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| Court membership | |
| Case opinions | |
| Majority | Kennedy, joined by Roberts, Scalia, Thomas, Alito |
| Dissent | Souter, joined by Stevens, Ginsburg, Breyer |
| Dissent | Breyer |
| Laws applied | |
| Fed. R. Civ. P. 8 (a)(2), 12 (b)(6) | |
Top government officials are not liable for the actions of their subordinates absent evidence that they ordered the allegedly discriminatory activity.
Ashcroft v. Iqbal, 556 U.S. 662 (2009), was a United States Supreme Court case in which the Court held that top government officials were not liable for the actions of their subordinates absent evidence that they ordered the allegedly discriminatory activity. At issue was whether current and former federal officials, including FBI Director Robert Mueller and former United States Attorney General John Ashcroft, were entitled to qualified immunity against an allegation that they knew of or condoned racial and religious discrimination against individuals detained after the September 11 attacks. The decision "transformed civil litigation in the federal courts" by making it much easier for courts to dismiss individuals' suits.
Javad Iqbal, a Pakistani-American cable television installer from Hicksville, New York, was arrested in New York in November 2001, on charges of conspiracy to defraud the United States and fraud in relation to identification documents (violations of 18 U.S.C. §§ 371 and 1028) and placed in pretrial detention at the Metropolitan Detention Center in Brooklyn, New York. He alleged that FBI officials carried out a discriminatory policy by designating him as a person "of high interest" in the investigation of the September 11 attacks solely because of his race, religion, or national origin. Owing to this designation he was placed in the detention center's Administrative Maximum Special Housing Unit for over six months while awaiting the fraud trial. Iqbal claimed that on the day he was transferred to the special unit, prison guards, without provocation, "picked him up and threw him against the wall, kicked him in the stomach, punched him in the face, and dragged him across the room." He said that after being attacked a second time he sought medical attention but was denied care for two weeks. According to Iqbal’s complaint, prison staff in the special unit subjected him to unjustified strip and body cavity searches, verbally berated him as a "terrorist" and "Muslim killer," refused to give him adequate food, and intentionally turned on air conditioning during the winter and heating during the summer, He claimed that prison staff interfered with his attempts to pray and engage in religious study, and with his access to counsel. Mr. Iqbal pleaded guilty to using another man's Social Security card on April 22, 2002, served a prison term until his release on January 15, 2003, and was later deported to Pakistan.
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