Group III: Pleadings and Motions · Last amended March 1, 2017 · Last verified July 14, 2026
(a) Claims for Relief. — A pleading that states a claim for relief must contain:
(1) a short and plain statement of the grounds for the court’s jurisdiction, unless the court already has jurisdiction and the claim needs no new jurisdictional support;
(2) a short and plain statement of the claim showing that the pleader is entitled to relief; and
(3) a demand for the relief sought, which may include relief in the alternative or different types of relief.
(b) Defenses; Admissions and Denials. —
(1) In General. — In responding to a pleading, a party must:
(A) state in short and plain terms its defenses to each claim asserted against it; and
(B) admit or deny the allegations asserted against it by an opposing party.
(2) Denials — Responding to the Substance. — A denial must fairly respond to the substance of the allegation.
(3) General and Specific Denials. — A party that intends in good faith to deny all the allegations of a pleading — including the jurisdictional grounds — may do so by a general denial subject to the obligations set forth in Rule 11. A party that does not intend to deny all the allegations must either specifically deny designated allegations or generally deny all except those specifically admitted.
(4) Denying Part of an Allegation. — A party that intends in good faith to deny only part of an allegation must admit the part that is true and deny the rest.
(5) Lacking Knowledge or Information. — A party that lacks knowledge or information sufficient to form a belief about the truth of an allegation must so state, and the statement has the effect of a denial.
(6) Effect of Failing to Deny. — An allegation — other than one relating to the amount of damages — is admitted if a responsive pleading is required and the allegation is not denied. If a responsive pleading is not required, an allegation is considered denied or avoided.
(c) Affirmative Defenses. —
(1) In General. — In responding to a pleading, a party must affirmatively state any avoidance or affirmative defense, including: accord and satisfaction; arbitration and award; assumption of risk; contributory negligence; duress; estoppel; failure of consideration; fraud; illegality; injury by fellow servant; laches; license; payment; release; res judicata; statute of frauds; statute of limitations; and waiver.
(2) Mistaken Designation. — If a party mistakenly designates a defense as a counterclaim, or a counterclaim as a defense, the court must, if justice requires, treat the pleading as though it were correctly designated, and may impose terms for doing so. discharge in bankruptcy;
(d) Pleading to be Concise and Direct; Alternative Statements; Inconsistency.
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(1) In General. — Each allegation must be simple, concise, and direct. No technical form is required.
(2) Alternative Statements of a Claim or Defense. — A party may set out two or more statements of a claim or defense alternatively or hypothetically, either in a single count or defense or in separate ones. If a party makes alternative statements, the pleading is sufficient if any one of them is sufficient.
(3) Inconsistent Claims or Defenses. — A party may state as many separate claims or defenses as it has, regardless of consistency.
(e) Construing Pleadings. — Pleadings must be construed so as to do justice.
Added February 2, 2017, effective March 1, 2017.
A complaint under Rule 8 needs three things: a short and plain basis for the court's jurisdiction, a short and plain statement showing the plaintiff is entitled to relief, and a demand for that relief. Responding parties must address each allegation — admitting it, denying it, or stating they lack enough information to know either way, which counts as a denial. A party can deny everything with a general denial, deny specific paragraphs while admitting the rest, or admit part of an allegation while denying the remainder. Allegations left unanswered are treated as admitted, except claims about the amount of damages.
The rule also requires a party to affirmatively plead recognized defenses — things like statute of limitations, waiver, duress, or res judicata — rather than let them surface later. If a party mislabels a defense as a counterclaim or the reverse, the court can fix the label when justice calls for it. Beyond that, Rule 8 favors simplicity: allegations should be direct, parties may plead alternative or even inconsistent claims and defenses, and every pleading gets read in a way that serves justice rather than trips up the pleader on technicalities.