West Case Update

Class of One May Claim Violation of Equal Protection Clause

Description Supreme Court held that one person, as a "class of one," could sue a government for violation of the equal protection clause. A governmental unit treated plaintiff differently from others similarly situated, and there was no rational basis for the treatment.

Topic Constitutional Law

Key Words Equal Protection; Class of One

C A S E S U M M A R Y

Facts Homeowner Olech asked the Village of Willowbrook to connect her property to the municipal water supply. The Village demanded Olech grant it a 33-foot easement. After an argument, the Village agreed to provide water service if Olech granted the Village a 15-foot easement, which was done. Olech sued the Village, claiming that the demand of the longer easement violated the Equal Protection Clause of the 14th Amendment because the demand was irrational and arbitrary and in retaliation for an earlier dispute between Olech and the Village. The district court dismissed the suit for failure to state a claim. The appeals court reversed. The Village appealed.

Decision Affirmed. The purpose of the equal protection clause is to secure every person within the State's jurisdiction against intentional and arbitrary discrimination, whether imposed by express terms of a statute or by its improper execution through its agents. An equal protection clause case may be brought by a "class of one," where plaintiff has been intentionally treated differently from others similarly situated and there is no rational basis for the difference in treatment. Here the Village demanded a 33-foot easement from Olech, when it only demanded a 15-foot easement of similarly situated property owners.

Citation Village of Willowbrook v. Olech, 120 S.Ct. 1073 (2000)

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Class of One May Claim Violation of Equal Protection Clause
Description	Supreme Court held that one person, as a "class of one," could sue a government for violation of the equal protection clause. A governmental unit treated plaintiff differently from others similarly situated, and there was no rational basis for the treatment.
Topic	Constitutional Law
Key Words	Equal Protection; Class of One
C A S E S U M M A R Y
Facts	Homeowner Olech asked the Village of Willowbrook to connect her property to the municipal water supply. The Village demanded Olech grant it a 33-foot easement. After an argument, the Village agreed to provide water service if Olech granted the Village a 15-foot easement, which was done. Olech sued the Village, claiming that the demand of the longer easement violated the Equal Protection Clause of the 14th Amendment because the demand was irrational and arbitrary and in retaliation for an earlier dispute between Olech and the Village. The district court dismissed the suit for failure to state a claim. The appeals court reversed. The Village appealed.
Decision	Affirmed. The purpose of the equal protection clause is to secure every person within the State's jurisdiction against intentional and arbitrary discrimination, whether imposed by express terms of a statute or by its improper execution through its agents. An equal protection clause case may be brought by a "class of one," where plaintiff has been intentionally treated differently from others similarly situated and there is no rational basis for the difference in treatment. Here the Village demanded a 33-foot easement from Olech, when it only demanded a 15-foot easement of similarly situated property owners.
Citation	Village of Willowbrook v. Olech, 120 S.Ct. 1073 (2000)