If the jeweler's complaint simply asserts 'drove negligently' in a federal diversity action, is it sufficient under federal pleading standards?

• A. Yes, it satisfies federal notice pleading
• B. No, because it does not satisfy federal pleading requirements
• C. No, because state pleading applies
• D. Yes, it satisfies state notice pleading in State B

Answer: (B)

Under federal pleading rules, a complaint must plead enough factual detail to make a claim plausible, not just label the conduct. After Twombly and Iqbal, a bare assertion like “drove negligently” is a legal conclusion with no supporting facts. It provides no details about what happened, when and where it occurred, what duty was owed, how that duty was breached, or how the breach caused injury. Without those facts, the complaint fails to give the defendant notice and fails to show a plausible basis for liability.

In a diversity action, the federal court applies federal procedural rules for pleading, even though substantive issues may be governed by state law under Erie. State pleading standards do not replace federal pleading requirements. So simply alleging negligence by stating the conduct is not enough under federal rules.

If the complaint included specific facts—what happened, when, where, who was involved, the duty, the breach, and the causal link to damages—it could satisfy the pleading standard.