District of Columbia Raises the Threshold for a Complaint to Survive a Motion to Dismiss

The District of Columbia will now require, in order to avoid dismissal, that a complaint must provide amble and well-pleaded factual content, from which, the court can draw a reasonable inference of the defendant’s liability for the misconduct alleged.

In Mazza v. Housecraft, L.L.C., 18 A.3d 786, (D.C. 2011), the Court of Appeals for the District of Columbia adopted the two-prong heightened pleading standard articulated in Bell Atlantic v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009). On appeal, the Court of Appeals affirmed the trial court’s dismissal of Anthony Mazza’s (“Mazza”) complaint on res judicata grounds, and further held that the pleading requirements articulated in Twombly and Iqbal now apply in the District of Columbia.

In 2004, Anthony Mazza entered into a home improvement contract with Housecraft L.L.C. (“Housecraft”) for the purpose of renovating Mazza’s property. When Mazza failed to pay the final invoice, as stipulated in the contract, Housecraft filed a mechanic’s lien against the property. The trial court entered judgment in favor of Housecraft. Mazza failed to satisfy the judgment, and subsequently, the Clerk of the Superior Court issued a writ to enforce the mechanic’s lien on Mazza’s property.

On May 15, 2009, Mazza filed a complaint challenging the enforcement of the mechanic’s lien. Mazza challenged the validity of the home improvement contract and the resulting mechanic’s lien on the ground that Mazza himself had not signed that contract; instead, Mazza’s wife had signed. Housecraft filed a motion to dismiss Mazza’s complaint on res judicata grounds, because, in previous litigation, the court had found a home improvement contract existed as between Mazza and Housecraft. The trial court agreed with Housecraft, and granted the motion to dismiss. Mazza filed a notice of appeal. In a de novo review, the Court of Appeals for the District of Columbia affirmed the trial court’s decision to grant the dismissal, and, for the first time, considered whether to adopt the heightened pleading standards articulated in Twombly and Iqbal.

In Twombly, the Supreme Court held that a complaint must allege “enough facts to state a claim to relief that is plausible on its face.”  The Court in Iqbal elaborated on Twombly, requiring that pleadings, subject to this standard, demand “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” In Iqbal, the Supreme Court developed a two-prong test for determining whether a civil complaint is sufficient to survive a motion to dismiss for failure to state a claim; specifically, “(1) whether the complaint includes well-pleaded factual allegations as an initial matter, and (2) whether such allegations plausibly give rise to an entitlement for relief.”  By adopting the Twombly and Iqbal standards, the District of Columbia will now require that Plaintiffs provide well-pleaded facts and allegations in the Complaint to avoid a motion to dismiss. 

Article contributed by Andy Nichols