Royal v. Pawtucket School Committee et al

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
PATRICIA ROYAL,
Plaintiff,
v.
PAWTUCKET SCHOOL
COMMITTEE, by and through the
School Committee Chair, et al.,
Defendants.
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C.A. No. 25-cv-113-MRD-AEM
ORDER
This case arises from Plaintiff Patricia Royal’s experience applying for and
acting as Superintendent of the Pawtucket School District. 	Before the Court is
Defendants’ Motion to Dismiss the Second Amended Complaint. 	ECF No. 29. 	The
motion seeks to dismiss Plaintiff’s Second Amended Complaint in its entirety for
violation of Federal Rule of Civil Procedure 8.
Id. Specifically, Defendants complain
that “Plaintiff’s Second Amended Complaint, at 141 pages and well over one thousand
(1,000) paragraphs, plainly violates Rule[ ] 8 . . . .” 	ECF No. 29-1 at 7. 	Plaintiff
defends the length of her pleading, responding that “[t]he extensiveness of the
unlawful acts, the severity and pervasiveness—compounded by the number of alleged
bad actors—would understandably make this complaint longer than the ‘typical’
employment claim.” 	ECF No. 30-1 at 2. 	Having reviewed the Second Amended
Complaint in its entirety, this Court concludes that Defendants’ motion will be
DENIED.
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To state a claim, Rule 8 requires only “a short and plain statement of the claim
showing that the pleader is entitled to relief.” 	Fed. R. Civ. P. 8(a)(2). 	The Rule
demands each allegation to be “simple, concise, and direct.” 	Fed. R. Civ. P. 8(d)(1).
To meet the minimum pleading standard, a complaint need only give each defendant
fair notice of the claims against them as to allow them to mount a defense.
Bell Atl.
Corp. v. Twombly, 550 U.S. 544, 555 (2007). 	While a detailed telling of facts is not
required, “the complaint should at least set forth minimal facts as to who did what to
whom, 	when, 	where, 	and 	why[.]” 	Educadores
	Puertorriquenos 	en 	Accion 	v.
Hernandez, 367 F.3d 61, 68 (1st Cir. 2004). 	That said, courts have long considered
that a complaint may violate Rule 8 if it is too long, wordy, and confusing.
McCoy v.
Providence J. Co., 190 F.2d 760, 766 (1st Cir. 1951). Such a complaint should only be
dismissed if it is so unclear and/or convoluted that the Court and answering
defendants are unable to discern the basis of the plaintiff’s claims.
Miranda v. United
States, 105 Fed. App’x 280, 281 (1st Cir. 2004) (per curiam). 	Whether to dismiss a
complaint for failure to comply with Rule 8 is within the district court’s discretion.
Kuehl v. F.D.I.C., 8 F.3d 905, 908 (1st Cir. 1993).
At over 140 pages, Plaintiff’s Second Amended Complaint is indisputably long.
See ECF No. 28. 	Indeed, this Court has previously concluded that “unnecessary
length places an unjustified burden on the court and on the party who must respond
to it.”
	Laurence v. Wall, No. CA 07–081 ML, 2007 WL 1875794, at *1 (D.R.I. June
27, 2007) (citing 5 Charles A. Wright & Arthur R. Miller, Federal Practice, and
Procedure § 1281 at 709 (3d ed. 2004)). 	However, because courts in this Circuit
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determine whether a complaint violates Rule 8 on a case-by-case basis and look to a
variety of factors in doing so, length (or any one factor) is not dispositive.1	
See, e.g.,
Kuehl, 8 F.3d at 908 (stating “[w]ere plaintiffs’ confessed overdrafting their only sin,
we would be inclined to agree that dismissal was an overly harsh penalty”). 	The
factors the court considers include: the nature of the case, the number of parties
involved, whether the complaint is redundant, the length of the complaint, the
organization of the complaint, prejudice, burden, and other pragmatic considerations.
Von Smith v. Al Thani, No. 20-2151, 2022 WL 2092505, at *1 (1st Cir. Feb. 14, 2022)
(length, redundancy, pragmatic concerns, prejudice, burden);
Jackson v. Polaroid
Corp., 181 F.3d 79 (1st Cir. 1999) (unpublished table decision) (same);
see also
Federal Practice, and Procedure § 1217 at 240–41 (“What constitutes a short and
plain statement must be determined in each case on the basis of the nature of the
action, the relief sought, and the respective positions of the parties in terms of the
availability of information and a number of other pragmatic matters.”).
Application of these factors to the instant case supports denying Defendants’
motion. Considering first the nature of the action, this case involves a range of state
law and federal claims against multiple entities and state actors in their individual
and official capacities.
See generally ECF No. 28. By the numbers, Plaintiff asserts
15 counts against 15 named Defendants.
	Id. 	Additionally, many of the claims she
1 This factor approach is within the spirit of the federal rules, which “promote
disposition of litigation on the merits rather than on the basis of technicalities.”
Kuehl, 8 F.3d at 908.
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asserts are factually complicated, including her constitutional claims and those
brought under various state and federal statutes.
Id. While the sections of the Second
Amended Complaint explaining the bases of these claims are dense and drawn out,
they are not difficult to understand.
	Id. 	Turning next to the Second Amended
Complaint’s organization, the document reads chronologically.
	Id. 	Its structure is
clear and easy to follow. 	This organization lessens Defendants’ burden because it
removes the need for them to piece together a timeline of events. 	Lastly, moving
forward on the Second Amended Complaint would not prejudice Defendants. 	This
case is unlike cases in which courts have dismissed a complaint for being “prolix,
disjointed, [and] replete with legal conclusions,”
Miranda, 105 Fed. App’x at 280, as
the Court does not find the Second Amended Complaint to be “a chaotic pastiche of
irrelevant, confusing disconnected averments” or “a conglomeration of allegations
made unintelligible by its volume, morass of irrelevancies, lack of clarity and its
incorporation-by-reference information overload,”
Peabody v. Griggs, No. CIV.A. 08-
243-ML, 2009 WL 3200686, at *10, *11 (D.R.I. Oct. 6, 2009).
Recognizing 	that 	there 	are 	some 	facets 	of 	Plaintiff’s 	Second 	Amended
Complaint which could, in isolation, support dismissal under Rule 8, this Court does
not consider the pleading in its entirety to be in “gross violation” of the Rule.2 	The
Second Amended Complaint is not so unclear or convoluted that the basis of the
2 	While the Court has concluded that portions of the Second Amended
Complaint could be deemed redundant, vague and conclusory, they have not risen to
a Rule 8 violation despite coming perilously close. The decision to deny Defendants’
motion was a close call. The Court encourages Plaintiff to be mindful of this moving
forward.
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claims cannot be discerned. 	Accordingly, the parties are directed to proceed in this
case on the Second Amended Complaint. Defendants’ motion to dismiss (ECF No. 29)
is DENIED.
IT IS SO ORDERED.
_________________________________
Melissa R. DuBose
United States District Judge
1/16/2026
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