Nyra Jean Miller-Fields, Individually and as Personal Representative of the Estate of Ricky Cobb, II v. Ryan Londregan, et al.

Precedent teaches that when a court considers a motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure, it should “accept as true the factual allegations in . . . [the] complaint.” Ashcroft v. al-Kidd, 563 U.S. 731, 734, 131 S. Ct. 2074, 2079, 179 L. Ed. 2d 1149 (2011). With law enforcement agencies’ widespread adoption of body-worn cameras, federal courts have increasingly grappled with an additional question in dealing with motions to dismiss because of qualified immunity: What effect do those videos have on the requirement that federal courts accept as true the allegations of a complaint? Drawing on precedent from this Court, the courts of appeal have largely concluded that these videos can be considered to the extent that they “blatantly contradict” the facts pled by the complaint. However, there appear to be differences about how courts should interpret this standard. The question presented by this case squarely addresses that issue: Under what circumstances should a court consider video in a Rule 12(b)(6) motion based on qualified immunity, and what standards should a federal court use to evaluate whether a video “blatantly contradicts” the facts alleged in a complaint?