civil rights law most responsible for African-American enfranchisement."  At The Nation , Brentin Mock also weighs in on the grant, arguing that "[a]ll that matters is that [the case] is being made before Chief Justice John Roberts' Supreme Court, which has shown no sympathy, if not shown flat-out resentment, for laws they believe support racial preference."  And in an op-ed for the Washington Examiner , Scott Douglas Gerber suggests that with the grant in Shelby County , "the current term also became [Justice] Thomas's best chance for leaving a lasting legacy on American law." Continue reading  In May 2009, the Supreme Court issued its decision in Ashcroft v. Iqbal , which explicitly extended the "plausibility standard," first articulated in Bell Atlantic v. Twombly two years earlier, to all civil pleadings.  That standard requires that pleadings, to satisfy Federal Rule of Civil Procedure 8(a), must state a plausible claim for relief.  For many, these rulings represented a sea change in civil pleading standards.  Where prior Supreme Court precedent had provided that a pleading should not be dismissed "unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim," the new standard requires that judges utilize their own "judicial experience and common sense" to determine whether claimants have set forth facts sufficient to "nudge[] their claims across the line from conceivable to plausible."