Opinion · Supreme Court of the United States
Village of Willowbrook v. Olech
528 U.S. 562
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 2000-02-23
- Topic
- general
How later courts describe this case
- holding that such a violation may occur when the government singles an individual out for irrational and arbitrary treatment
- holding that a “class of one” may have an actionable equal protection claim, whether facial or as applied in nature
- holding that Equal Protection Clause is violated when government treats individual differently from others similarly situated without any rational basis
- holding that to establish as class-of-one, a plaintiff must show that the defendant intentionally treated him differently from others similarly situated without a rational basis
- holding that those who are not members of a protected class may bring an equal protection claim under a theory of a “class of one”
- holding that the standard under the Equal Protection Clause of the Nevada Constitution is the same as the federal standard
- holding that in civil rights actions, the plaintiff need not meet a heightened pleading standard, but rather must simply comply with Rule 8(a)(2
- holding that a lack of rational basis 9 for differential treatment can give rise to an equal protection claim
Citator
UpLaw has not yet analyzed Village of Willowbrook v. Olech. The absence of a flag is not a finding that it is good law.
- Authority status
- pending
- Cited by
- 3777 opinions
- Distinguished
- 1 times
Headnotes
- Constitutional Law — Equal Protection The Equal Protection Clause permits a "class of one" claim where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment.
- Constitutional Law — Equal Protection The purpose of the Equal Protection Clause of the Fourteenth Amendment is to secure every person within the State's jurisdiction against intentional and arbitrary discrimination, whether occasioned by express terms of a statute or by its improper execution through duly constituted agents.
- Constitutional Law — Equal Protection A complaint states a claim for relief under traditional equal protection analysis where it alleges that the defendant intentionally treated the plaintiff differently from similarly situated persons and that the defendant's demand was irrational and wholly arbitrary; such allegations are sufficient quite apart from the defendant's subjective motivation.
- Constitutional Law — Equal Protection The number of individuals in a class is immaterial for equal protection analysis; whether a complaint alleges a class of one or of five is of no consequence.
Respondent Grace Oleeh and her late husband Thaddeus asked petitioner Village of Willowbrook (Village) to connect their property to the municipal water supply. The Village at first conditioned the connection on the Olechs granting the Village a 33-foot easement. The Olechs objected, claiming that the Village only required a 15-foot easement from other property owners seeking access to the water supply. After a 3-month delay, the Village relented and agreed to provide water service with only a 15-foot easement.
Oleeh sued the Village, claiming that the Village’s demand of an additional 18-foot easement violated the Equal Protection Clause of the Fourteenth Amendment. Oleeh asserted that the 33-foot easement demand was “irrational and wholly arbitrary”; that the Village’s demand was actually motivated by ill will resulting from the Olechs’ previous filing of an unrelated, successful lawsuit against the Village; and that the Village acted either with the intent to deprive Oleeh of her rights or in reckless disregard of her rights. App. 10, 12.
The District Court dismissed the lawsuit pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a cognizable claim under the Equal Protection Clause. Relying on Circuit precedent, the Court of Appeals for the Sev
Our cases have recognized successful equal protection claims brought by a “class of one,” where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment. See Sioux City Bridge Co. v. Dakota County, 260 U. S. 441 (1923); Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U. S. 336 (1989). In so doing, we have explained that “‘[t]he purpose of the equal protection clause of the Fourteenth Amendment is to secure every person within the State’s jurisdiction against intentional and arbitrary discrimination, whether occasioned by express terms of a statute or by its improper execution through duly constituted agents.’ ” Sioux City Bridge Co., supra, at 445 (quoting Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 352 (1918)).
It is so ordered.
We note that the complaint in this case could be read to allege a class of five. In addition to Grace and Thaddeus Olech, their neighbors Rodney and Phyllis Zimmer and Howard Brinkman requested to be connected to the municipal water supply, and the Village initially demanded the 33-foot easement from all of them. The Zimmers and Mr. Brinkman were also involved in the previous, successful lawsuit against the Village, which allegedly created the ill will motivating the excessive easement demand. Whether the complaint alleges a class of one or of five is of no consequence because we conclude that the number of individuals in a class is immaterial for equal protection analysis.