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District of Columbia Adopts Heightened Civil Pleading Standard

Mazza v. Housecraft LLC
Case No. 09-CV-1068 (D.C. 2011)

by Imran O. Shaukat, Summer Associate
Semmes, Bowen & Semmes (

In Mazza v. Housecraft LLC, the Court of Appeals for the District of Columbia officially adopted the heightened civil pleading standard articulated in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009). Specifically, the Court held that Anthony Mazza (“Mazza”) failed to state a claim upon which relief could be granted when his Complaint relied on allegations barred by res judicata.

By way of background, the Supreme Court held in Twombly that a Complaint is insufficient unless it alleges “enough facts to state a claim to relief that is plausible on its face.” 550 U.S. at 570. In Iqbal, the Court clarified the new pleading standard by providing a two-part test to determine whether a Complaint is sufficient to survive a Motion to Dismiss: (1) whether the Complaint includes well-pleaded factual allegations as an initial matter, and (2) whether such allegations plausibly give rise to an entitlement for relief. To meet this heightened pleading standard, FED. R. CIV. P. 8(a) “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Iqbal, 129 S. Ct. at 1949.

Here, Housecraft LLC (“Housecraft”) entered into a home improvement contract with Mazza to renovate Mazza’s property (the “Property”). When Mazza failed to pay the total amount of the final invoice, Housecraft filed a mechanic’s lien against the Property. The trial court, finding for Housecraft, issued a writ of fieri facias to enforce the mechanic’s lien.

Mazza argued that because only his wife signed the contract for the renovations, the mechanic’s lien could not be executed against the Property, which was held solely in Mazza’s name. Housecraft filed a Motion to Dismiss, arguing that, on res judicata grounds, Mazza could not allege that the contract between the parties was flawed because, in previous litigation, a contract was found to exist. The trial court, agreeing with Housecraft, granted the Motion to Dismiss.

On appeal, the Court of Appeals for the District of Columbia affirmed the trial court’s decision. In recognizing that the District of Columbia had not yet decided whether to adopt the pleading requirements articulated in Twombly and Iqbal, the Court compared FED. R. CIV. P. 8(a) with the District of Columbia’s equivalent, SUPER. CT. CIV. R. 8(a). Finding that SUPER. CT. CIV. R. 8(a) mirrors its federal counterpart, the Court concluded that the requirements articulated in Twombly and Iqbal for a Complaint to survive a Motion to Dismiss apply in the District of Columbia.