In Johnson v. City of Shelby, 135 S. Ct. 346 (U.S. 2014) (No. 13-1318), former city employees brought suit against the City, alleging they were terminated in violation of due process. The district court granted summary judgment in favor of the City, and the Fifth Circuit affirmed, ruling that plaintiffs’ complaint was insufficient to state a claim because it failed to invoke 42 U.S.C. § 1983, the statute under which they sought damages. The U.S. Supreme Court granted plaintiffs’ petition for a writ of certiorari and, in a per curium opinion, summarily reversed. The Court held that the federal pleading rules require only a short and plain statement of the claim showing that the pleader is entitled to relief; “they do not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim asserted.” The Court reasoned that its decisions inBell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009), were not on point because “they concern the factual allegations a complaint must contain to survive a motion to dismiss.” Having adequately informed the City of the factual basis for their complaint, plaintiffs were required to do no more to stave off threshold dismissal for failure to state a claim.