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Where no fundamental right exists and the party alleging an equal protection violation is not among the suspect classes recognized by the courts, the classification challenged will be upheld if it bears a rational relationship to a legitimate governmental purpose. If the court can discern any reasonable basis for the classification, it will be upheld. This test for constitutional validity is often referred to as the rational basis test.
Plaintiff trustee, Mount Prospect State Bank, owned a parcel of land on which it established a mobile home park that housed between 70 and 77 mobile homes. Defendant, the Village of Kirkland, contracted with a refuse collection company for garbage collection service for the village's residences. The contract specifically excluded the plaintiff’s mobile home park, which was the only mobile home park in the village. The plaintiff filed an action seeking an order of mandamus compelling the village to provide garbage collection for the mobile home park. The plaintiff argued that its exclusion was discriminatory and violated the plaintiff’s right to equal protection. The plaintiff also sought punitive damages under 42 U.S.C.S. § 1983 and compensatory damages for the years in which garbage service was denied but the plaintiff paid taxes to the village. The trial court granted the village's motion to dismiss and the plaintiff sought review.
Did the defendant’s refuse collection policy arbitrarily discriminated against mobile home parks, thereby resulting in the violation of plaintiff’s right to equal protection of the laws?
The court affirmed the trial court’s dismissal of the plaintiff’s action, finding that there was no right to garbage collection and that the plaintiff was not among the recognized suspect classes. The court also found that there was a rational basis for the exclusion of the plaintiff and that the action was therefore properly dismissed.