Facts
- Grace Olech sought connection of her home to the Village of Willowbrook’s municipal water supply.
- The Village conditioned service on Olech granting a 33-foot easement.
- Olech alleged the Village typically required only a 15-foot easement from similarly situated property owners requesting water connection.
- After about three months, the Village agreed to connect Olech’s property in exchange for a 15-foot easement.
- Olech sued, alleging the 33-foot demand was intentional, arbitrary, and irrational, and that the Village acted with improper motives tied to the Olechs’ prior successful lawsuit against the Village.
- Olech asserted an Equal Protection Clause violation based on being singled out for different treatment, despite not alleging membership in any protected class.
Issues
- Whether the Equal Protection Clause permits a “class of one” claim where a plaintiff alleges intentional disparate treatment from similarly situated persons without a rational basis, despite no allegation of membership in a class or group.
- Whether allegations of intentional, irrational differential treatment in a municipal service/easement demand state an equal protection claim at the pleading stage.
Decision
- The Supreme Court affirmed the judgment of the Seventh Circuit and held that a “class of one” equal protection claim is cognizable.
- The Court ruled that a plaintiff states such a claim by alleging (1) intentional different treatment from others similarly situated and (2) the absence of a rational basis for the difference.
- The Court held Olech’s allegations were sufficient under traditional equal protection analysis, independent of any showing of subjective ill will.
- The Court declined to decide whether a separate “subjective ill will” or “spite” theory was required or sufficient.
Legal Principles
- The Equal Protection Clause protects individuals from intentional and arbitrary discrimination, including discrimination carried out through the actions of government officials.
- A “class of one” claim may proceed without alleging membership in a protected class if the plaintiff alleges intentional disparate treatment of similarly situated persons and no rational basis for that differential treatment.
- At the pleading stage, allegations of intentional differential treatment combined with an asserted lack of rational basis can state a claim, even without proving or relying on officials’ subjective motives.
Conclusion
The Court recognized that equal protection liability can arise when government intentionally treats an individual differently from similarly situated persons without any rational basis, allowing “class of one” claims to proceed even absent membership in a protected class.