The Supreme Court of the United States announced two per curiam decisions yesterday:

Johnson v. City of Shelby, No. 13-1318: Petitioners brought a lawsuit against the city of Shelby, Mississippi, seeking compensatory relief on allegations that their Fourteenth Amendment due process rights were violated when they were fired by the city’s board of aldermen, not for deficient performance, but because they brought to light criminal activities of one of the aldermen. The District Court entered summary judgment against the Petitioners, and the Fifth Circuit affirmed, because of the complaint’s failure to invoke 42 U.S.C. §1983. The Court summarily reversed, holding that the pleading requirement under Federal Rule of Civil Procedure 8(a)(2) does not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim asserted. In the opinion, the Court’s prior decisions in Bell Atlantic v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009) were expressly distinguished as concerning the separate issue of the factual allegations a complaint must contain to survive a motion to dismiss.

The Court's decision is available here.

Carroll v. Carman, No. 14-212: Plaintiffs brought a Section 1983 lawsuit against Officer Carroll, alleging that he unlawfully entered their property in violation of the Fourth Amendment when he went into their backyard and onto their deck without a warrant. Carroll argued at trial that his entry was lawful under the “knock and talk” exception to the warrant requirement, which permits officers to knock on someone’s door, so long as they stay on those portions of the property where the general public is allowed to go. Plaintiffs responded that the exception did not apply because a normal visitor would have gone to their front door, not into their backyard and the deck. The jury returned a verdict for Officer Carroll, which the Third Circuit reversed, holding that Carroll violated the Fourth Amendment as a matter of law because the “knock and talk” exception requires an officer to go to the front door. The Court reversed, holding that Carroll was entitled to qualified immunity because, regardless of whether the constitutional rule applied by the court below was correct, it was not beyond debate.

The Court's decision is available here.