The Sixth Circuit Court of Appeals held the allegations of a complaint were sufficient under Iqbal and Twombly pleading requirements. In Victoria A. Jackson v. Ford Motor Company, 842 F.3d 902 (6th Cir. 2016) the widow of a motorist who died in a car accident sued the car manufacturer alleging that the car was equipped with a defective electronic power steering system (EPAS) that caused the motorist to lose control of the car. Ford filed a motion to dismiss on the ground that the amended complaint did not sufficiently plead causation. The district court granted the motion and held that the amended complaint consisted of “conclusory statements regarding proximate cause” and then specified the deficiencies in the pleading. The plaintiff appealed the dismissal.
The Court of Appeals noted that Ford did not dispute that the plaintiff’s Amended Complaint plausibly pleads a defect in the EPAS system. The court then reviewed the test under Tennessee law for proximate cause and said “?the district court demanded too much of Jackson under the familiar Iqbal and Twombly pleading requirements. Accordingly we reverse the district court’s judgment dismissing the complaint and remand the case for further proceedings.” (842 F.3d @ 905)