Background
Rashad Ranzy, proceeding pro se, appealed a district court order that adopted a magistrate judge’s recommendation to dismiss his complaint. The underlying complaint alleged that the defendant, James Scott Farrin, violated Ranzy’s rights under the American with Disabilities Act. The district court conducted review under Section nineteen hundred fifteen of Title twenty-eight of the United States Code.
The court’s reasoning
The court reviewed the record and found no reversible error. Citing Francis v. Giacomelli, the court noted that naked assertions of wrongdoing require factual enhancement within the complaint to cross the line between possibility and plausibility of entitlement to relief. The court determined the complaint failed to meet this standard.
[N]aked assertions of wrongdoing necessitate some factual enhancement within the complaint to cross the line between possibility and plausibility of entitlement to relief.
Francis v. Giacomelli, 588 F.3d 186, 193 (4th Cir. 2009)
What it means going forward
The dismissal of the ADA claim stands, and the plaintiff’s allegations were deemed insufficient to state a plausible claim for relief under the applicable pleading standards.
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