Open Justice Baltimore, et al. v. Baltimore City Law Department, et al.

The Federal Rules of Civil Procedure set forth a liberal pleading standard. Fed. R. Civ. P. 8(a). This Court has clarified that the Rules create a plausibility pleading standard, meaning that the complaint must allege “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When faced with a motion to dismiss, courts are bound to accept well-pleaded facts as true and draw all reasonable inferences in favor of the nonmoving party. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A complaint can survive a motion to dismiss “even if it strikes a savvy judge that actual proof of those facts is improbable, and ‘that a recovery is very remote and unlikely.’” Id. at 556 (citation omitted). A defendant may prevail on a motion to dismiss when an obvious alternative explanation exists; however, courts cannot simply credit a proffered justification over a plaintiff’s allegations because of the overarching requirement that courts consider allegations as a whole, accept well-pleaded facts as true, and draw all reasonable inferences in favor of the nonmoving party. Nat’l Rifle Ass’n of Am. v. Vullo, 602 U.S. 175, 195–97 (2024) (citing Twombly 550 U.S. at 570 and Iqbal, 556 U.S. at 678). Accordingly, the question presented is: W hether a defendant who offers a competing alternative explanation for conduct alleged in a plaintiff’s complaint bears the burden of showing that their alternative explanation renders the plaintiff’s theory of liability implausible.