SunPower Corporation v. Sunpower California, LLC
- Proceeding
- district
- Area
- civil
- Panel
- Cathy Ann Bencivengo (author)
Analysis
Defendant Benjamin Jackson moved for a more definite statement and to strike the complaint against him. The court denied the motion, finding the complaint met the plausibility standard, and ordered Jackson to file an answer by May 6, 2021.
| What the court decided | The model |
|---|---|
Motion for a more definite statement and motion to strike denied“Accordingly, the motion for a more definite statement to strike the complaint is DENIED.” | agree with court The court applied the plausibility standard from Iqbal and Twombly to determine that the complaint contained sufficient factual matter to state a claim against Jackson. While the court noted it could not discern cogent legal argument for dismissal, the application of the pleading standard to deny a motion for a more definite statement (which typically requires a showing that the pleading is so confusing that it prevents the opposing party from responding) is a defensible procedural outcome, though the order conflates the standard for a 12(b)(6) motion with the standard for a Rule 12(e) motion. |
The order itself: sound with gaps — The order is procedurally sound in its result but contains a gap in its reasoning. The court denies a motion for a more definite statement (Rule 12(e)) by applying the plausibility standard for a motion to dismiss (Rule 12(b)(6)). While the result (denial) is likely correct if the complaint is plausible, the legal test for a motion for a more definite statement is distinct (whether the pleading is so unintelligible that the opposing party cannot reasonably respond). The court does not explicitly address the Rule 12(e) standard, relying instead on the 12(b)(6) standard, which is a gap in the legal analysis.
Opinion
1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 10 SUNPOWER CORPORATION, Case No.: 21-CV-375-CAB-MSB 11 Plaintiff, ORDER DENYING MOTION FOR A 12 v. MORE DEFINITE STATEMENT AND MOTION TO STRIKE 13 SUNPOWER CALIFORNIA, LLC;
GREEN TECH SOLAR d/b/a Sunpower 14 California; and Benjamin Jackson, [Doc. No. 12] 15 Defendants. 16 17 18 19 This matter is before the Court on Defendant Benjamin Jackson’s motion for a more 20 definite statement and motion to strike the complaint as to claims against him. The motion 21 has been fully briefed, and the Court deems it suitable for submission without oral 22 argument. Upon review of the motion, the Court is unable to discern any cogent legal 23 argument for dismissing Plaintiff’s claims against Jackson, which is the outcome Jackson 24 seeks notwithstanding the title of his motion. In any event, the Court finds that the 25 complaint contains “sufficient factual matter, accepted as true, to ‘state a claim to relief 26 that is plausible on its face’” against Jackson, Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) 27 (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)), and that a more 28 definite statement is not warranted. Accordingly, the motion for a more definite statement | to strike the complaint is DENIED. Jackson shall file his answer to the complaint by 2 || May 6, 2021. 3 Itis SO ORDERED. 4 ||Dated: April 21, 2021 € Z 5 Hon. Cathy Ann Bencivengo 6 United States District Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28