Lexplug logoLexplug

Village of Willowbrook v. Olech

United States Supreme Court
528 U.S. 562 (2000)
ELI5:

Rule of Law:

The Equal Protection Clause of the Fourteenth Amendment gives rise to a cause of action on behalf of a "class of one" where the plaintiff alleges they have been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment. Proof of subjective ill will or animus is not a necessary element of such a claim.


Facts:

  • Grace Olech and her husband Thaddeus asked the Village of Willowbrook to connect their property to the municipal water supply.
  • The Olechs had previously been successful in an unrelated lawsuit against the Village.
  • As a condition for the connection, the Village demanded that the Olechs grant a 33-foot easement over their property.
  • The Village's standard requirement for such water connections from other similarly situated property owners was only a 15-foot easement.
  • The Olechs objected to the demand for the larger easement.
  • After a three-month delay, the Village relented and agreed to provide the water service with the standard 15-foot easement.

Procedural Posture:

  • Grace Olech sued the Village of Willowbrook in U.S. District Court, claiming a violation of the Equal Protection Clause.
  • The District Court dismissed the lawsuit for failure to state a claim upon which relief could be granted.
  • Olech, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Seventh Circuit.
  • The Court of Appeals reversed the District Court's decision, holding that Olech's complaint was sufficient to state a claim.
  • The Village of Willowbrook, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the Equal Protection Clause give rise to a cause of action on behalf of a 'class of one' where a plaintiff alleges intentional and arbitrary differential treatment, but does not allege membership in a protected class or group?


Opinions:

Majority - Per Curiam

Yes. The Equal Protection Clause protects a 'class of one' where the plaintiff alleges they have been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment. The purpose of the Equal Protection Clause is to secure all persons against intentional and arbitrary discrimination, whether by statute or by its improper execution by government agents. Olech's complaint sufficiently stated a claim by alleging that the Village intentionally demanded a 33-foot easement where it only required a 15-foot easement from others, and that this demand was 'irrational and wholly arbitrary.' These allegations, standing alone, are sufficient to state a claim under traditional equal protection analysis, without regard to the Village's subjective motivation or 'ill will.'


Concurring - Justice Breyer

Yes. While agreeing with the outcome, this opinion expresses concern that the majority's holding could transform ordinary violations of state or local law, such as zoning mistakes, into constitutional claims. In this specific case, that concern is minimized because Olech alleged an extra factor: 'vindictive action' or 'illegitimate animus' on the part of the Village, stemming from a previous lawsuit. The presence of this additional allegation of ill will is sufficient to distinguish the case from a run-of-the-mill administrative error and justifies finding a potential constitutional violation.



Analysis:

This decision formally establishes the 'class of one' theory of equal protection, clarifying that an individual does not need to be a member of a protected class to bring a claim. By basing the claim on the lack of a rational basis for differential treatment, the Court lowered the bar for such claims, as plaintiffs do not necessarily need to prove subjective ill will or malicious intent. Justice Breyer's concurrence highlights the primary tension created by this ruling: the potential for federal courts to become embroiled in routine local administrative disputes, turning every alleged arbitrary zoning or permit decision into a constitutional case.

🤖 Gunnerbot:
Query Village of Willowbrook v. Olech (2000) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Village of Willowbrook v. Olech