Sheppard v. David Evans & Assoc., 694 F.3d 1045 (9th Cir. 2012)

Kathryn Sheppard filed a brief, two-and-a-half page complaint in federal court alleging discrimination under the Age Discrimination in Employment Act (“ADEA”) and wrongful termination under Oregon state law. The district court dismissed Sheppard’s complaint with prejudice under FRCP 8(a)(2) after concluding she had failed to plead a cause of action with sufficient factual detail to state a claim. The Ninth Circuit reversed, holding that under Ashcroft v. Iqbal, 556 U.S. 662 (2009), a complaint need not contain “detailed factual allegations.”