The Law School Authority

Leatherman v. Tarrant County Case Brief

Summary of Leatherman v. Tarrant County
507 U.S. 163 (1993)

Facts:  Two Ps brought actions against the county for violations of their civil rights.  Ps claimed that police officers violated their civil rights by improperly serving search warrants of their homes.

Procedure:  The 5th Circuit Court of Appeals had adopted a heightened pleading standard when it came to lawsuits involving municipality liability.  The district court dismissed Ps’ complaints and the Court of Appeals affirmed.

Issue: Can a court adopt special heightened standards of pleading for certain categories of cases?

Holding:  No

Rationale: Federal Rules of Civil Procedure follow the notice pleading standard.  A complaint need only put the court and the defendant on notice of the causes of action.  For proper notice, a complaint only need to present a short and plain statement of the claim showing that the pleader is entitled to relief.  A court may not adopt heightened standards of pleading for certain cases when under FRCP, no such standard is implemented.  Reversed.

**Special matters (e.g. fraud, mistake or special damages) must be pleaded with more specificity.

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