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Law School Case Brief

Engquist v. Or. Dep't of Agric. - 553 U.S. 591, 128 S. Ct. 2146 (2008)


The Fourteenth Amendment requires that all persons subjected to legislation shall be treated alike, under like circumstances and conditions, both in the privileges conferred and in the liabilities imposed. When those who appear similarly situated are nevertheless treated differently, the Equal Protection Clause requires at least a rational reason for the difference, to assure that all persons subject to legislation or regulation are indeed being treated alike, under like circumstances and conditions. Thus, when it appears that an individual is being singled out by the government, the specter of arbitrary classification is fairly raised, and the Equal Protection Clause requires a rational basis for the difference in treatment.


Petitioner Anup Engquist, an Oregon public employee, filed suit against respondents, her agency, her supervisor, and a co-worker, asserting, inter alia, claims under the Equal Protection Clause. More specifically, Engquist alleged that she had been discriminated against based on her race, sex, and national origin, and she also brought a so-called "class-of-one" claim, alleging that she was fired not because she was a member of an identified class (unlike her race, sex, and national origin claims), but simply for arbitrary, vindictive, and malicious reasons. The jury rejected the class-membership equal protection claims, but found for Engquist on her class-of-one claim.  The United States Court of Appeals for the Ninth Circuit reversed the jury's verdict and award for the employee on the class-of-one claim. Certiorari was granted to resolve a disagreement in the lower courts over such claims.


Was the ruling in Village of Willowbrok v. Olech (528 U.S. 562 [2000]) applicable to “class of one” equal protection claims against government bodies under public employment context?




Affirming the judgment of the Court of Appeals for the Ninth Circuit, the United States Supreme Court concluded that recognition of a class-of-one theory of equal protection in the public employment context was contrary to the concept of at-will employment; the Constitution did not require repudiating the at-will doctrine. Recognizing the sort of claim the employee was pressing could have jeopardized the delicate balance governments have struck between the rights of public employees and the government's legitimate purpose in promoting efficiency and integrity in the discharge of official duties and in maintaining proper discipline in the public service. Government offices could not function if every employment decision became a constitutional matter and ratifying a class-of-one theory in the context of public employment would have impermissibly constitutionalized the employee grievance.

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