## Facts

- Mount Prospect State Bank (the Bank) owned a parcel of property within the Village of Kirkland, Illinois, that contained approximately 70 to 77 mobile homes.
- The Village provided municipal garbage-collection services to about 317 residences located in the Village.
- The Village did not provide municipal garbage-collection services to the mobile homes located on the Bank’s property.
- The Bank filed suit alleging that excluding the mobile homes from the Village’s garbage-collection service, while providing the service to other residences, denied equal protection.
- The Village moved to dismiss the complaint, and the trial court granted the motion.
- The Bank appealed from the dismissal.

## Issues

1. Whether the Bank’s complaint stated an equal protection claim based on the Village’s refusal to provide municipal garbage-collection services to the mobile homes while providing such services to other residences in the Village.

## Decision

- The Illinois Appellate Court affirmed the trial court’s dismissal of the complaint.
- The court held that, under rational-basis equal protection review, the Bank failed to state a claim that the Village’s service classification was unconstitutional.
- Because the complaint did not plead facts that would overcome the presumption that municipal service classifications are valid if any rational basis can support them, dismissal on the pleadings was proper.

## Legal Principles

- Equal protection generally requires that similarly situated persons be treated alike, but it does not forbid government line-drawing; it bars only classifications that are arbitrary under the governing standard of review.
- Where no suspect class or fundamental right is involved, a municipal classification is reviewed under rational-basis scrutiny and will be upheld if it is rationally related to a legitimate governmental purpose.
- Under rational-basis review, a municipal policy may stand if any reasonably conceivable set of facts could support it; the government need not show the best or most precise fit between means and ends.
- Municipalities have broad authority to structure and finance public services such as refuse collection, including setting service categories and determining which properties receive municipal collection.
- A complaint challenging a municipal classification must allege more than unequal outcomes; it must plead facts showing the classification is wholly arbitrary and cannot be justified by legitimate considerations such as cost, logistics, administrative feasibility, or other operational differences.
- On a motion to dismiss, courts accept well-pleaded factual allegations as true, but they need not accept legal conclusions, and dismissal is warranted if the pleaded facts, even if true, do not state a constitutional violation under the applicable deferential standard.

## Conclusion

The appellate court affirmed dismissal of the Bank’s equal protection challenge to the Village’s refusal to provide garbage collection to the Bank’s mobile-home property, holding that the complaint did not state a constitutional claim under rational-basis review because municipal service classifications are presumed valid if they can be supported by any legitimate governmental reason.


Mount Prospect State Bank v. Village of Kirkland, 467 N.E.2d 1142 (1984)