“‘Twas Three Years After Twombly and All Through the Bar, Not a Plaintiff Was Troubled From Near or From Far”—The Unremarkable Effect of the U.S. Supreme Court’s Re-Expressed Pleading Standard in Bell Atlantic Corp. v. Twombly

This Article describes FRCP Rule 8’s origin and explains its intended application; chronicles Rule 8’s history of restriction and misapplication, and the Supreme Court’s contribution to ensuring Rule 8’s treatment in a manner consistent with its drafters’ intentions; then examines Twombly, focusing on the Court’s consideration, expression, and application of Rule 8’s pleading standard in more modern circumstances; and explains how the Twombly Court reaffirmed the intentions of Rule 8’s drafters and re-expressed Rule 8’s liberal pleading requirements