In an opinion yesterday, Judge Swain dismissed a case brought by a subcontractor who worked on the SDNY courthouse and claims to have been underpaid by $20 million. She found the complaint lacked even the most basic details required under Rule 8:

[The plaintiff] alleges generally that it believes it is owed more than $20,000,000 for . . . additional work, but the Complaint contains no specific factual allegations relating to the nature of the additional work and expenses, or the calculation of this additional sum . . . .

A broad, unsupported, and conclusory statement that a defendant owes more money than was paid under a contract is precisely the type of ‘naked assertion’ of a claim that does not suffice . . . .