Iqbal Court: Twombly Applies Beyond Antitrust Context

One debate that has persisted among some scholars regarding the import of Twombly has been settled by the Supreme Court in Monday's decision in Ashcroft v. Iqbal: whether the Twombly standard can be limited to antitrust cases:

"Respondent first says that our decision in Twombly should be limited to pleadings made in the context of an antitrust dispute. This argument is not supported by Twombly and is incompatible with the Federal Rules of Civil Procedure. Though Twombly determined the sufficiency of a complaint sounding in antitrust, the decision was based on our interpretation and application of Rule 8. 550 U. S., at 554. That Rule in turn governs the pleading standard “in all civil actions and proceedings in the United States district courts.” Fed. Rule Civ. Proc. 1. Our decision in Twombly expounded the pleading stan-dard for “all civil actions,” ibid., and it applies to antitrust and discrimination suits alike. See 550 U. S., at 555-556, and n. 3."