Litigation in Federal Court

Pleadings & Motions

Pleadings Allowed

FRCP 7(a): Pleadings Allowed

[1] Plaintiff’s Complaint

[2] Defendant’s Answer

Other Counter/Crossclaims

Plaintiff’s Complaint

FRCP 8(a): Plaintiff’s Complaint

• The plaintiff’s complaint must include:

[1] Jurisdiction

[2] Claim for Relief

[3] Demand for Relief

Twiqbal Rule:

• In response to a 12(b)(6) motion, the court will ask if the plaintiff’s complaint:

[1] avoids conclusory statements

[2] states plausible claims

Defendant’s Answer

FRCP 8(b): Defendant’s Answer

• The defendant’s answer must:

[1] state defenses to each claim in short and plain terms

[2] admit (affirmative defense) or deny the allegations in the complaint.

FRCP 8(c): the defendant’s right to raise an affirmative defense is waived if not stated in their answer.

FRCP 12: Motion Practice

(b): Defendant’s options for dismissal before filing an answer.

[1] Subject Matter Jurisdiction

[2] Personal Jurisdiction

[3] Venue

[4] Process (technical issues)

[5] Service

[6] Failure to State a Claim

[7] Failure to Join a Party (FRCP 19)

(c-f): Defendant’s other options for dismissal early in the case.

[c] Motion for Judgment on Pleadings (same as 12(b)(6), but after filing an answer)

[d] Motion to Dismiss (with evidence before discovery)

[e] Motion for More Definite Statement

[f] Motion to Strike

Counterclaims and Crossclaims

FRCP 13: Counterclaims and Crossclaims

[a] Compulsory Counterclaim:

• Pleadings must state any counterclaims arising from the same transaction as the original claim. Allows supplemental jurisdiction unless it destroys diversity.

[b] Permissive Counterclaim:

• Pleadings may also state any non-compulsory counterclaim not arising from the same transaction, but supplemental jurisdiction won’t apply.

[c] Crossclaim Against a Coparty:

• A crossclaim against a coparty is only permitted if it arises out of the same transaction as the (1) original claim or (2) counterclaim.

[d] Allows non-parties to be added.

Third Party Practice

FRCP 14(a): Impleader

• The Defendant (as a third party Plaintiff) can implead a nonparty liable to it for the claim they’re facing, but they must obtain the court’s leave if filing more than 14 days after their answer.  

Amending Pleadings

FRCP 15(a): Amending Pleadings

[1] Amendments as a Matter of Course: available within 21 days of service or the Defendant’s answer

[2] Other Amendments: available with consent of the court or the other party.