During the past three years, the U.S. Supreme Court has raised the standards for the specificity of pleadings in Ashcroft v. Iqbal,1 Tellabs Inc. v. Makor Issues & Rights, Ltd.,2 and Bell Atlantic Corp. v. Twombly.3 Courts and commentators have focused generally on the implications of those decisions for motions to dismiss, rather than motions for summary judgment.
But the reasoning underlying Iqbal, Tellabs and Twombly also has affected summary judgment analysis, notwithstanding that courts traditionally have deemed the standards for these two motions to be separate and distinct.
