Willowbrook v. Olech
| Decision Date | 23 February 2000 |
| Docket Number | No. 98-1288,98-1288 |
| Citation | 120 S. Ct. 1073,528 U.S. 562 |
| Parties | VILLAGE OF WILLOWBROOK, ET AL., PETITIONERS v. GRACE OLECH |
| Court | U.S. Supreme Court |
PRIOR HISTORY: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT.
COUNSEL: James L. DeAno argued the cause for petitioners.
Irving L. Gornstein argued the cause for the United States, as amicus curiae, by special leave of court.
John R. Wimmer argued the case for respondent.
Respondent Grace Olech and her late husband Thaddeus asked petitioner Village of Willowbrook 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.
Olech sued the Village claiming that the Village's demand of an additional 18-foot easement violated the Equal Protection Clause of the Fourteenth Amendment. Olech 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 Olech 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 Seventh 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 (CA7 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. *
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, 67 L. Ed. 340, 43 S. Ct. 190 (1923); Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U.S. 336, 102 L. Ed. 2d 688, 109 S. Ct. 633 (1989). In so doing, we have explained that "'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.'" Sioux City Bridge Co., supra, at 445 (quoting Sunday Lake Iron Co. v. Township of Wakefield, 247 U.S. 350, 352, 62 L. Ed. 1154, 38 S. Ct. 495 (1918)).
That reasoning is applicable to this case. Olech'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, 2 L. Ed. 2d 80, 78 S. Ct. 99 (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.
CONCUR
...
To continue reading
Request your trial
-
Hayden v. Alabama Dep't of Public Safety, Civil Action No. 2:06cv948-ID (WO).
...... class, Defendants are correct that he must proceed under the equal protection "class of one" theory first announced in Village of Willowbrook v. Olech, 528 U.S. 562, 120 S.Ct. 1073, 145 L.Ed.2d 1060 (2000) (per curiam). Defendants, however, argue that the Olech class-of-one theory should ......
-
Olivia Y. ex rel. Johnson v. Barbour, No. CIV.A.3:04 CV 251LN.
...... standard as requiring a discriminatory animus against a preexisting class was flatly rejected by the Supreme Court in Village of Willowbrook v. Olech, 528 U.S. 562, 120 S.Ct. 1073, 145 L.Ed.2d 1060 (2000), and they conclude that because defendants' position rests entirely on an erroneous ......
-
Alarcon v. Davey
...... Engquist v . Oregon Department of Agriculture , 553 U.S. 591, 601-02 (2008); Village of Willowbrook v . Olech , 528 U.S. 562, 564 (2000); San Antonio School District v . Rodriguez , 411 U.S. 1 (1972); Lazy Y Ranch Ltd . v . Behrens , 546 F.3d ......
-
Adkins v. Kernan
...... not relate to a legitimate penological purpose. See. Village of Willowbrook v. Olech , 528 U.S. 562, 564. (2000) (holding that equal protection claims may be brought. by a “class of one”); Reese v. Jefferson ......
-
Ninth Circuit's Recalibration Of Equal Protection Favors Businesses
...Olech v. Village of Willowbrook, 160 F. 3d 386, 388 (7th Cir. 1998). 362023 WL 2544853, *10. 37See, e.g., Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (per curiam); Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U.S. 336 (1989); Sioux City Bridge Co. v. Dakota Coun......
-
Cleaning Up the Rest of Agins: Bringing Coherence to Temporary Takings Jurisprudence and Jettisoning 'Extraordinary Delay
...which, in all fairness and justice, should be borne by the public as a whole,” 263 than scenarios 256. Village of Willowbrook v. Olech, 528 U.S. 562, 30 ELR 20360 (2000) (equal protection claims not limited to protected classes). See generally , Robert C. Farrell, Classes, Persons, Equal Pr......
-
The 'Euclidean' Strategy: Authorizing and Implementing the Legislative Districting of Permissible Land Uses
...There are exceptions to the prevailing pattern, however, most notably the per curium decision in Village of Willowbrook v. Olech, 528 U.S. 562, 564-65 (2000). The Olechs, who had successfully sued the village over another matter, brought an equal protection challenge when the village condit......
-
Reforming Qualified-Immunity Appeals.
...equal-protection claims must show that the discrimination they suffered lacked a rational basis. Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000); see also William D. Araiza, Flunking the Class-of-One/Failing Equal Protection, 55 WM. & MARY L. REV. 435, 438 ("Class-of-one claim......
-
A REIGN OF ERROR: PROPERTY RIGHTS AND STARE DECISIS.
...a city undertakes such intrusive regulation of the family, ... the usual judicial deference to the legislature is inappropriate."). (35.) 528 U.S. 562 (2000) (per (36.) Id. at 565. (37.) Id. at 563. (38.) Id. at 564. (39.) Id. (40.) William D. Araiza, Irrationality and Animus in Class-of-On......