Federal Rule of Civil Procedure 12(b)(6)

Did the Texas Supreme Court substitute fair notice pleading for well-pleaded complaints?  Texas Rule of Civil Procedure 91a was adopted in 2013, and provides a “no reasonable person could believe” standard.  Until recently, whether “no reasonable person could believe” meant “plausibility” remained an unanswered question.  In City of Dallas v. Sanchez, No. 15-0094 (July 1,