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liability based on such policy or custom must still satisfy ― the
usual requirements of notice pleading specified by the Federal
Rules.‖ Jordan, 15 F.3d at 339. Such pleading standard
requires ―more than labels and conclusions, and a formulaic
recitation of the elements of a cause of action wil l not do.‖
Francis, 588 F.3d at 193 (quoting Twombly, 550 U.S. at 555). It
is insufficient for a plaintiff to present ―‗naked assertions‘
of wrongdoing ‖ because without facts to support such conclusory
statements, the unadorned claims fail to ―cross ‗ the line
between possibility and plausibility of entitlement to relief. ‘‖
Id. (quoting Twombly, 550 U.S. at 557); see Revene v. Charles
Cnty. Com m‘rs, 882 F.2d 870, 875 (4th Cir. 1989) (―§ 1983
complaints which on critical elements of a claim me rely recite
legal conclusions wholly devoid of facts, may prope rly be
dismissed for insufficiency of statement .‖) (internal quotation
marks and citations omitted).
Here, Plaintiff alleges that the City and the Newpo rt News
Police Department have a ―policy and custom . . . o f using
excessive and reckless force in dealing with citize ns and in
handling suspects . . . . ‖ Compl. ¶ 15. Plaintiff fails,
however, to present a single fact to support her co nclusory
statements regarding the existence of an official p olicy or
custom related to the treatment of suspects by Newp ort News
Police officers. Rather, Plaintiff advances the wh olly Jump to an indexed page (39 of 39)