Opinion · Supreme Court of the United States

Village of Willowbrook v. Olech

13 Fla. L. Weekly Fed. S 105

Type: Opinion
Court: Supreme Court of the United States
Jurisdiction: Federal
Date: 2000-02-23
Topic: general

holding that such a violation may occur when the government singles an individual out for irrational and arbitrary treatment | 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 | holding that plaintiff homeowner could assert an equal protection claim where village demanded a 33-foot easement, while requiring 15-foot easements from similarly situated property owners | holding that a homeowner alleging that she was arbitrarily deprived of a water connection because of ill will generated by prior litigation stated a claim for relief under rational equal protection analysis | holding that there are “two essential elements of [a] ‘class of one’ equal protection claim: (1) disparate treatment of similarly situated parties (2) on no rational basis.” | holding that in order to establish a class-of-one equal protection claim a plaintiff must show that (1) the defendants treated him differently than others similarly situated, (2 | holding that a “class of one” may assert an equal protection claim | holding that a "class of one" may assert an equal protection claim | holding that equal protection claims may be brought by a “class 3 of one” | holding that equal protection 25 claims may be brought by a “class of one” | holding that equal protection claims may be 11 brought by a “class of one” | holding that equal 1 protection claims may be brought by a “class of one” | holding that equal protection claims may be brought by a “class 19 of one” | recognizing that the Equal Protection Clause is violated when a person is “intentionally treated differently from others similarly situated and ... there is no rational basis for the difference in treatment” | holding that a homeowner could assert an equal protection claim as a class of one against a village that demanded a 33-foot easement to connect her property to municipal water supply | recognizing that plaintiff states valid class-of-one equal protection claim where she “alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment” | holding that a plaintiff asserts a valid equal protection claim when he (i) is a member of a protected class and was treated differently from members of an unprotected class, or (ii | holding that to state a successful equal protection claim on a class-of-one theory, the plaintiff must allege “that there is no rational basis for the difference in treatment” from others similarly situated | holding that neither prisoners nor indigents are suspect classes for equal protection purposes | holding that equal protection claims may be brought by a “class of one” | holding that equal protection claims may be brought by a “class of one” | holding that equal protection claims may be brought by a “class of one” | holding that a party establishes an equal protection violation where he shows that he "has been intentionally treated differently from others s

Citator

Authority status: pending
Cited by: 3318 opinions
Distinguished: 1 times

Per Curiam.

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 *564 enth Circuit reversed, holding that a plaintiff can allege an equal protection violation by asserting that state action was motivated solely by a “ ‘spiteful effort to “get” him for reasons wholly unrelated to any legitimate state objective.’” 160 F. 3d 386, 387 (1998) (quoting Esmail v. Macrane, 53 F. 3d 176, 180 (CA7 1995)). It determined that Olech’s complaint sufficiently alleged such a claim. 160 F. 3d, at 388. We granted certiorari to determine whether the Equal Protection Clause gives rise to a cause of action on behalf of a “class of one” where the plaintiff did not allege membership in a class or group.* 527 U. S. 1067 (1999).

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)).

*565 That reasoning is applicable to this ease. Oleeh’s complaint can fairly be construed as alleging that the Village intentionally demanded a 33-foot easement as a condition of connecting her property to the municipal water supply where the Village required only a 15-foot easement from other similarly situated property owners. See Conley v. Gibson, 355 U. S. 41, 45-46 (1957). The complaint also alleged that the Village’s demand was “irrational and wholly arbitrary” and that the Village ultimately connected her property after receiving a clearly adequate 15-foot easement. These allegations, quite apart from the Village’s subjective motivation, are sufficient to state a claim for relief under traditional equal protection analysis. We therefore affirm the judgment of the Court of Appeals, but do not reach the alternative theory of “subjective ill will” relied on by that court.

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.