This Article proceeds chronologically. Part I describes pleading from 1938 until 1983 under the notice pleading regime put in place by the drafters of the Federal Rules of Civil Procedure. Part II surveys the harsh features of the 1983 amendments to Rule 11 and the effect it had on pleading. Part III details the 1993 amendments to Rule 11 that restored notice pleading. Part IV discusses the Twombly and Iqbal decisions and the important ways in which they changed pleading. Part V then explores the significant similarities between the 1983–1993 era of pleading and the post-Iqbal era, including the implications of this historical link.
