Law School Case Brief
Willowbrook v. Olech - 528 U.S. 562, 120 S. Ct. 1073 (2000)
Equal protection claims are successfully 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.
A married couple asked a village to connect their property to the municipal water supply. After the couple objected to the village's conditioning of the connection on the couple's granting the village a 33-foot easement--where the couple asserted that the village required only a 15-foot easement from other property owners who sought access to the water supply--the village, following some delay, agreed to provide the couple water service with a 15-foot easement. The wife, whose husband had died, brought against the village in a Federal District Court a suit alleging that the village's demand of an additional 18-foot easement had violated the equal protection clause of the Federal Constitution's Fourteenth Amendment. The wife, who did not allege membership in a class or group, asserted that (1) the 33-foot easement demand was (a) "irrational and wholly arbitrary," (b) motivated by ill will resulting from the couple's previous filing of an unrelated unsuccessful lawsuit against the village; and (2) the village had acted either (a) with the intent to deprive the wife of her rights, or (b) in reckless disregard of her rights. The District Court dismissed the suit pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure for failure to state a cognizable claim under the equal protection clause. The United States Court of Appeals for the Seventh Circuit, in reversing, expressed the view that the wife's complaint alleged an equal protection claim by asserting that the village's action was motivated solely by spite.
Did the homeowner allege a cognizable claim under the Equal Protection Clause of the Fourteenth Amendment?
The Court held that, although the homeowner constituted a class of one member, she had successfully stated a cognizable equal protection claim, so the Court was not required to determine whether the municipality's retaliation for the homeowner's previous unrelated lawsuit presented an equal protection violation.
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