Webb v. Nashville Area Habitat for Humanity, Inc.
Annotate this CaseAfter Pam Webb, who was employed by the Nashville Area Habitat for Humanity, was fired, Webb filed a complaint alleging retaliatory discharge. Habitat filed a motion to dismiss Webb's complaint for failure to state a claim upon which relief can be granted pursuant to Tenn. R. Civ. P. 12.02(6). Webb filed an amended complaint, and Habitat responded by filing an amended Rule 12.02(6) motion to dismiss. The trial court granted Habitat's motion and dismissed the amended complaint on all claims. The court of appeals vacated the trial court's judgment, holding that the amended complaint sufficiently stated a cause of action for retaliatory discharge. The Supreme Court granted review. At issue was the proper standard for Tennessee courts to apply in ruling on a Rule 12.02(6) motion to dismiss and whether the Court should adopt the pleading standard set forth in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, which retired the notice pleading regime recognized in Conley v. Gibson in favor of a new plausibility pleading standard. The Supreme Court declined to adopt the new Twombly/Iqbal plausibility pleading standard and affirmed the judgment of the court of appeals.
Court Description: In this action alleging retaliatory discharge, the trial court granted the defendant s motion to dismiss for failure to state a claim upon which relief can be granted pursuant to Tennessee Rule of Civil Procedure 12.02(6). The Court of Appeals vacated the trial court s judgment, holding that the amended complaint sufficiently stated a cause of action for retaliatory discharge. We address the issue of the proper standard for Tennessee courts to apply in ruling on a Rule 12.02(6) motion to dismiss in light of the United States Supreme Court s recent decisions in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, ___ U.S. ___, 129 S. Ct. 1937 (2009). We decline to adopt the new Twombly/Iqbal plausibility pleading standard and affirm the judgment of the Court of Appeals.
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