In the case of William Erickson v. Barry J. Pardus et al., 2006, plaintiff William Erickson, a Colorado state prisoner, filed a pro se complaint against prison officials for allegedly discontinuing his prescribed hepatitis C medication which he claimed was in violation of his Eighth Amendment rights to be free from cruel and unusual punishment. The District Court dismissed the claim as "unbelievable," and this decision was upheld by the Tenth Circuit Court on appeal. However, when brought before the Supreme Court, it ruled unanimously in favor of Erickson stating that under Federal Rule of Civil Procedure 8(a)(2), specific facts are not necessary; rather all that is required is a short plain statement showing entitlement to relief. The court stated that if there were doubts about plausibility they should be resolved in favor of plaintiff at this stage where dismissal is based solely on pleadings. The Supreme Court thus reversed previous rulings and remanded back to lower courts for further proceedings consistent with their opinion - reinforcing an important principle regarding access to justice especially for those who represent themselves (pro se litigants).

In the dissenting opinion for William Erickson v. Barry J. Pardus et al., Justice Thomas, joined by Justice Scalia, argued that the majority had misapplied the standard for dismissal of a complaint under Federal Rule of Civil Procedure 12(b)(6). The dissenters believed that Erickson's claim was not plausible and should have been dismissed because it lacked sufficient factual matter to suggest he was entitled to relief. They contended that his allegations were conclusory and did not meet the requirement of providing more than labels and conclusions or a formulaic recitation of elements of a cause action. Furthermore, they disagreed with the majority's view on how much detail is needed in a complaint to survive dismissal; they asserted that requiring specific facts would prevent frivolous lawsuits from proceeding further into litigation process.