Engquist v. Oregon Department of Agriculture
553 U.S. 591, 170 L. Ed. 2d 975, 2008 U.S. LEXIS 4705 (2008)
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Rule of Law:
The 'class-of-one' theory of equal protection, which allows a person to state a claim by alleging they were intentionally treated differently from other similarly situated individuals without a rational basis, does not apply in the context of public employment.
Facts:
- Anup Engquist was hired in 1992 as an international food standard specialist for the Oregon Department of Agriculture (ODA).
- Engquist experienced repeated conflicts with a coworker, Joseph Hyatt, and complained about him to her supervisor.
- In 2001, John Szczepanski became the supervisor for Engquist, Hyatt, and their manager, Norma Corristan.
- Szczepanski told a client he could not 'control' Engquist and that she and Corristan 'would be gotten rid of.'
- When both Engquist and Hyatt applied for a vacant managerial post, Szczepanski selected Hyatt, despite Engquist's greater experience.
- Later, Szczepanski eliminated Corristan's position during budget cuts.
- On January 31, 2002, Engquist was informed her position was being eliminated due to reorganization.
- Engquist was found unqualified for the only available 'bump' position at her level and declined a demotion, resulting in her being laid off.
Procedural Posture:
- Anup Engquist sued the Oregon Department of Agriculture (ODA), Szczepanski, and Hyatt in the U.S. District Court for the District of Oregon, asserting claims including a 'class-of-one' equal protection violation.
- The District Court allowed the class-of-one claim to proceed to trial.
- A jury found for Engquist on her class-of-one claim, finding the defendants treated her differently 'without any rational basis and solely for arbitrary, vindictive or malicious reasons,' and awarded her damages.
- The ODA and the individual defendants, as appellants, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the trial court's judgment, holding that the class-of-one theory of equal protection does not apply in the public employment context.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does the Equal Protection Clause of the Fourteenth Amendment allow a public employee to bring a 'class-of-one' claim alleging they were intentionally and irrationally treated differently from other similarly situated employees?
Opinions:
Majority - Chief Justice Roberts
No. The 'class-of-one' theory of equal protection does not apply in the public employment context. There is a crucial difference between the government acting as a sovereign regulator, where such claims are cognizable, and the government acting as a proprietor or employer. Government employment decisions are inherently discretionary, subjective, and individualized, resting on a wide array of factors that are difficult to articulate, such as personality and interpersonal relationships. Unlike regulatory actions where there is often a clear standard for equal treatment (as in Village of Willowbrook v. Olech), the employer-employee relationship lacks such a baseline, making the class-of-one theory a poor fit. Allowing such claims would 'constitutionalize the employee grievance,' inviting federal courts to micromanage the daily personnel decisions of public agencies and undermining the traditional concept of at-will employment.
Dissenting - Justice Stevens
Yes. A public employee should be able to bring a 'class-of-one' equal protection claim. The core purpose of the Equal Protection Clause is to protect all persons, including state employees, from intentional and arbitrary discrimination by the state that lacks any rational basis. The majority creates a novel exception for public employees, incorrectly suggesting that discretionary employment decisions cannot be arbitrary. There is a clear distinction between a discretionary choice among rational alternatives and an arbitrary decision with no rational basis at all. The jury in this case specifically found that Engquist was terminated for 'arbitrary, vindictive or malicious reasons' and without any rational basis, which is precisely the type of irrational state action the Fourteenth Amendment prohibits. Fear of excessive litigation is an insufficient reason to carve out a constitutional protection.
Analysis:
This decision significantly curtails the scope of the 'class-of-one' equal protection theory established in Village of Willowbrook v. Olech. By creating a categorical exception for the public employment context, the Court solidified a strong distinction between the government's role as sovereign versus its role as an employer. The ruling bars public employees from challenging personnel decisions as arbitrary or malicious under the Equal Protection Clause unless they can allege discrimination based on membership in a protected class (e.g., race, sex). This forces public employees to seek recourse for such grievances primarily through statutory protections, like civil service laws, rather than through direct constitutional claims.
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