## Facts

- Anup Engquist worked for the Oregon Department of Agriculture (ODA).
- Engquist sued ODA, her supervisor, and a coworker in federal court alleging, among other claims, Equal Protection violations based on race, sex, and national origin, and a “class-of-one” Equal Protection claim.
- The class-of-one claim asserted she was singled out and terminated for arbitrary, vindictive, and malicious reasons, rather than because of membership in a protected class.
- A jury rejected the protected-class Equal Protection claims but found for Engquist on the class-of-one claim and awarded damages.
- The Ninth Circuit reversed as to the class-of-one claim, holding that the class-of-one theory recognized in *Village of Willowbrook v. Olech* does not apply to public-employment personnel decisions.
- The Supreme Court granted certiorari to decide whether the class-of-one theory applies in public employment.

## Issues

1. Whether the Equal Protection Clause’s class-of-one theory applies to discretionary public-employment personnel actions such as hiring and firing.
2. Whether a public employee may challenge an allegedly arbitrary or vindictive termination as a class-of-one Equal Protection violation absent protected-class discrimination.

## Decision

- The Court affirmed the Ninth Circuit in a 6–3 decision authored by Chief Justice Roberts.
- The Court held that the class-of-one theory of Equal Protection does not apply in the public-employment context.
- The Court distinguished government action as employer from government action as regulator, concluding the government has broader discretion in managing its workforce.
- The Court reasoned that employment decisions are often subjective and individualized, making “similarly situated” comparisons ill-suited to constitutional class-of-one review.
- The Court emphasized administrability concerns: allowing such claims would convert routine personnel disputes into federal constitutional litigation and intrude on government workplace management.
- The dissent would have allowed class-of-one claims by public employees for irrational and wholly arbitrary treatment, viewing the Equal Protection principle as generally applicable.

## Legal Principles

- Class-of-one Equal Protection claims are categorically unavailable for challenges to discretionary public-employment personnel decisions.
- Equal Protection analysis may account for governmental role and context; the government receives greater leeway when acting as employer than when exercising regulatory authority over the public.
- Class-of-one claims remain available outside public employment where government action is rule-bound enough to permit meaningful comparison and rational-basis review (as in regulatory settings).
- Public employees retain other avenues for relief, including protected-class Equal Protection claims and statutory or constitutional claims addressing specific prohibited grounds for adverse action.

## Conclusion

The Supreme Court held that the Equal Protection Clause’s class-of-one doctrine does not extend to discretionary personnel decisions in public employment, insulating routine government workplace judgments from class-of-one constitutional challenges while leaving other antidiscrimination and constitutional protections intact.


Engquist v. Or. Dep’t of Agric., 553 U.S. 591 (2008)