In the 2014 case of Tracey L. Johnson, et al. v. City of Shelby, Mississippi, two police officers sued their former employer for wrongful termination due to racial discrimination under the Equal Protection Clause of the Fourteenth Amendment and federal law (42 U.S.C §1983). The city argued that they failed to cite this statute in their complaint which led lower courts to dismiss it on procedural grounds without addressing its merits. However, when appealed at Supreme Court level, a unanimous decision reversed this dismissal stating that no heightened pleading rule requires plaintiffs seeking damages for unconstitutional conduct need identify precise statutory provisions at issue in their complaint. The court emphasized that federal rules only require a short and plain statement showing entitlement to relief; specific legal theories are not necessary as long as defendants have fair notice about what claims are being made against them.

In the case of Tracey L. Johnson, et al. v. City of Shelby, Mississippi (2014), there was no dissenting opinion recorded as the decision was unanimous per curiam ruling in favor of the plaintiffs - two police officers who were fired without due process by their employer, City of Shelby. The Supreme Court ruled that even though they did not cite a specific statute in their initial complaint, it should not have been dismissed because it is clear from context that they were alleging a violation of procedural due process rights under 14th Amendment to U.S Constitution.