1. Would Twombly and Iqbal affect the result in American Nurses? Is it significant that federal civil rights cases have been dismissed at a higher rate than other cases under the standard of plausible pleading? See Schneider, The Changing Shape of Federal Civil Pretrial Practice: The Disparate Impact on Civil Rights and Employment Discrimination Cases, 158 U. Pa. L. Rev. 517 (2010). What factors might explain this trend? Do civil rights plaintiffs face unique information barriers to pleading facts with particularity? See Wasserman, Iqbal, Procedural Mismatches, and Civil Rights Litigation, 14 Lewis & Clark L. Rev. 157

(2010).