In Crawford-El v. Britton, 523 U.S. 574, 118 S. Ct. 1584 (1998), the Supreme Court rejected the D.C. Circuit's requirement that a plaintiff bringing a claim under section 1983 against a government official in his or her individual capacity, regarding which the official's improper motive is a necessary element, adduce "clear and convincing evidence" of such motive in order to defeat a motion for summary judgment. 118 S. Ct. at 1595. The Court of Appeals had adopted this heightened evidentiary requirement to protect government officials, in a doubtful case, from the burdens of discovery and trial. The Supreme Court held that the D.C. Circuit went too far in increasing the plaintiff's evidentiary burden. The Supreme Court said that it was "therefore appropriate to add a few words on some of the existing procedures available to federal trial judges in handling claims that involve examination of an official's state of mind." Id. at 1596. The Court stated that when a plaintiff files a complaint against a public official alleging a claim that requires proof of wrongful motive, the trial court must exercise its discretion in a way that protects the substance of the qualified immunity defense. It must exercise its discretion so that officials are not subjected to unnecessary and burdensome discovery or trial proceedings. Id. One way of accomplishing this, the Court went on, was for trial courts, prior to permitting any discovery, to use existing procedures, such as ordering a plaintiff to reply to a defendant's answer or granting defendant's motion for a more definite statement, to require that plaintiffs allege specific facts supporting an allegation of wrongful motive. Id. at 1596. The Supreme Court then stated, in unequivocal language directly relevant to the issue under consideration, that "the trial court may insist that the plaintiff 'put forward specific, nonconclusory factual allegations' that establish improper motive causing cognizable injury in order to survive a prediscovery motion for dismissal or summary judgment." Id. (quoting in part Siegert v. Gilley, 500 U.S. 226 , 236 (1991) (Kennedy, J., concurring in judgment)). "This option exists," the Court went on to state, "even if the official chooses not to plead the affirmative defense of qualified immunity." Id. at 1597. In Crawford-El, the Supreme Court recognized that claims against individual public officials have the potential to subject them to burdensome discovery and trials and stated that district judges may dispose of such claims prior to permitting any discovery where a plaintiff, having been provided the opportunity to do so, fails to allege "specific, nonconclusory factual allegations that establish improper motive." 118 S. Ct at 1596.