Edwards v. Marin Park, Inc., 356 F.3d 1058 (2004)

Citation: Edwards v. Marin Park, Inc., 356 F.3d 1058 (2004)
Parent Document: Edwards v. Marin Park, Inc., 356 F.3d 1058 (2004)
Jurisdiction: United States (federal)
Effective Date: 2004-01-26
Original Source: https://www.courtlistener.com/opinion/784956/edwards-v-marin-park-inc/ ↗

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Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002), instructs us that the standards for pleading discrimination claims are no higher than the relaxed notice pleading standard of Federal Rule of Civil Procedure 8(a), viz., a "short and plain statement of the claim showing that the pleader is entitled to relief." Swierkiewicz overruled the Second Circuit's practice of imposing, at the dismissal stage, the prima facie case framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). Swierkiewicz, 534 U.S. at 510-11, 122 S.Ct. 992. Rather than adduce a prima facie claim in the complaint itself — before discovery, often necessary to uncover a trail of evidence regarding the defendants' intent in undertaking allegedly discriminatory action, has taken place — a plaintiff need only "give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Swierkiewicz, 534 U.S. at 512, 122 S.Ct. 992 (quoting Conley, 355 U.S. at 47, 78 S.Ct. 99). The prima facie case is "an evidentiary standard, not a pleading requirement." Id. at 510, 122 S.Ct. 992. Failure to adduce it may result in a later loss at summary judgment, but failure to plead it does not support dismissal at the outset. Id. at 510, 514, 122 S.Ct. 992.

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