CLIENT ALERT: Minnesota Supreme Court Rejects More Stringent Twombly and Iqbal Pleading Standard


In Walsh v. U.S. Bank, N.A., A13-0742 (Aug. 6, 2014), the Minnesota Supreme Court declined to adopt the federal pleading standard of Twombly and Iqbal, which requires a pleader to state facts that render a claim plausible on its face. Instead, the supreme court held that Minnesota's rules of civil procedure still require courts to apply the traditional pleading standard, under which a claim survives a motion to dismiss if it is possible to grant the relief that the pleader requests on any facts that might be produced.  The supreme court interpreted Rule 8.01’s requirement that a complaint set forth “a short and plain statement of the claim showing that the pleader is entitled to relief.” Based on textual, historical, and contextual analysis of Rule 8.01, the supreme court declined to adopt a plausibility-based pleading standard.

By refusing to adopt the more stringent federal standard, the supreme court clarified that, to survive a motion to dismiss, complaints filed in Minnesota state courts need not be as detailed or precise as those filed in federal court.

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