Charles E. Clark and Simple Pleading: Against a 'Formalism of Generality'
34 Pages Posted: 24 Apr 2009 Last revised: 8 Apr 2011
Date Written: April 20, 2009
This paper explores Charles E. Clark's intent for the pleading standard under the Federal Rules of Civil Procedure. It argues that Clark rejected both notice pleading and rigidity, the two characteristics the predominated under the Federal Rules, at least before Bell Atlantic v. Twombly.
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