(2d Cir.1993). However, in Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit, 507 U.S. 163, 168, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993), the Supreme Court “held that a federal court may not apply a ‘heightened pleading standard’ in civil rights cases alleging municipal liability under section 1983.” Rheingold v. Harrison Town Police Dept., 568 F.Supp.2d 384, 394 (S.D.N.Y.2008) (citing Leatherman, 507 U.S. at 168, 113 S.Ct. 1160). Following Iqbal and Twombly, Monell claims must satisfy the plausibility standard: It is questionable whether the boilerplate Monell claim often included in many § 1983 cases, including this one, was ever sufficient to state a claim upon which relief could be granted. See Smith v. City of New York, 290 F.Supp.2d 317, 322 (E.D.N.Y.2003) (<HOLDING>). In light of Ashcroft v. Iqbal, 556 U.S. 662,
holding that making a nonfrivolous allegation is insufficient to survive a motion to dismiss for lack of jurisdiction holding that the bare assertion that a dismissal without prejudice was favorable to the plaintiff was insufficient to survive a motion to dismiss holding that a claim must be facially plausible in order to survive a motion to dismiss holding that a mere allegation of fraud is insufficient to survive a motion to dismiss pursuant to the pslra holding that a conclusory boilerplate assertion of a municipal policy or custom was insufficient to survive motion to dismiss