White v. Smith
91 F.R.D. 607, 33 Fed. R. Serv. 2d 536, 1981 U.S. Dist. LEXIS 15108 (1981)
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Rule of Law:
A general denial to a complaint is improper under Federal Rules of Civil Procedure 8(b) and 11 when it is not made in good faith and is interposed for delay, particularly when the complaint is specific, detailed, and supported by documents.
Facts:
- A prisoner, while in custody in New York, faced extradition to North Carolina.
- The prisoner filed a state habeas corpus petition to challenge the legality of his extradition.
- A New York state judge set a hearing date for the prisoner's habeas corpus petition.
- The prisoner was allegedly notified of this hearing date by prison official Doris Beitz.
- Before the scheduled court hearing could occur, New York correctional officials, including Acting Superintendent Scully, delivered the prisoner to North Carolina authorities.
Procedural Posture:
- The plaintiff filed a pro se civil rights action in the United States District Court.
- The court granted the plaintiff permission to proceed in forma pauperis.
- The complaint was served on the defendants, who are New York State employees.
- Defendants' attorney, an Assistant Attorney General, moved for and was granted an extension of time to answer.
- The defendants filed a joint 'form answer' containing a general denial of the plaintiff's claims.
- The court is now reviewing the sufficiency of that answer on its own initiative.
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Issue:
Does a boilerplate answer that generally denies all allegations in a specific and detailed pro se complaint, and which appears to have been filed for the purpose of delay, satisfy the pleading requirements of Federal Rules of Civil Procedure 8(b) and 11?
Opinions:
Majority - Elfvin, District Judge
No. A boilerplate answer that generally denies all allegations in a specific and detailed complaint does not satisfy federal pleading requirements. Federal Rule of Civil Procedure 8(b) requires that denials be specific, and while a general denial is permissible if made in good faith, the one filed here was not. The court reasoned that the plaintiff’s complaint was meticulously detailed with names, dates, and supporting documents, making it a simple matter for the defendants to admit or deny specific facts after reviewing their own records. The court found the defendants' general denial absurd and concluded it was not offered in good faith and was interposed for delay, in violation of Rule 11.
Analysis:
This decision serves as a strong admonition to attorneys, particularly government counsel, against the use of generic, unresponsive 'form answers' in civil litigation. It reinforces the principle that Rule 11's good faith requirement is not a mere formality and that pleadings must be based on a reasonable inquiry into the facts. The court's action of striking the answer, while stopping short of a default judgment, acts as a clear warning that such litigation tactics will face serious sanctions, ensuring that even pro se complaints receive meaningful and specific responses.
