Ipse Dixit Pleading after Iqbal
From Willey v. J.P. Morgan Chase, N.A., 2009 U.S. Dist. LEXIS 57826 (S.D.N.Y. July 7, 2009):
[I]pse dixit pleading is insufficient. *** Iqbal unequivocally rejects the notion that conclusory statements unsupported by factual allegations can subject a defendant to the burdens of discovery.
Quoted with approval in Tracy v. NVR, Inc., 2009 U.S. Dist. LEXIS 90778, 10-11 (W.D.N.Y. Sept. 30, 2009). See also Harris v. Mills, 572 F.3d 66, 75 (2d Cir. 2009) (affirming dismissal because “there is no allegation (beyond ipse dixit) that Harris was denied the opportunity to read from a written statement ‘by reason’ of his disability, let alone ‘solely by reason’ of his disability, as the Rehabilitation Act requires.”).
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