Case Citator › GJR Investments, Inc. v. County of Escambia

GJR Investments, Inc. v. County of Escambia

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Eleventh Circuit
Citation
132 F.3d 1359
Decided
Confirmed treatments
1
Flagged citations read
609 of 609
Citing cases (total)
1,133
Treatment dates
2010
Abrogated
A reviewed court treats this case as abrogated by later authority. GJR Investments, Inc. v. County of Escambia is abrogated in part: every flagged citation has been read, and the one confirmed treatment is listed below. Randall v. Scott recognized that Iqbal displaced GJR's heightened pleading requirement for Section 1983 defendants asserting qualified immunity.
More on how this was screened

The other opinions reported that act while continuing to apply GJR's surviving rules, including that liberal construction does not permit a court to rewrite a deficient pleading and its distinct municipal and individual-liability principles.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

1,133 later cases cite GJR Investments, Inc. v. County of Escambia; 609 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Eleventh Circuit recognized that Iqbal abrogated GJR's heightened Rule 8 pleading requirement for Section 1983 cases involving officials who may assert qualified immunity.

    Randall v. Scott · Eleventh Circuit · filed

    While Swann, GJR, and Danley reaffirm application of a heightened pleading standard for § 1983 cases involving defendants able to assert qualified immunity, we agree with Randall that those cases were effectively overturned by the Iqbal court. Pleadings for § 1983 cases involving defendants who are able to assert qualified immunity as a defense shall now be held to comply with the standards described in Iqbal. ... After Iqbal it is clear that there is no “heightened pleading standard” as it relates to cases governed by Rule 8(a)(2), including civil rights complaints. All that remains is the Rule 9 heightened pleading standard.
    Read the full opinion on CourtListener →

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