Village of Willowbrook v. Olechon

PETITIONER: Village of Willowbrook
RESPONDENT: Olechon
LOCATION: Massachusetts Office for Administration and Finance

DOCKET NO.: 98-1288
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 528 US 562 (2000)
ARGUED: Jan 10, 2000
DECIDED: Feb 23, 2000

ADVOCATES:
Irving L. Gornstein - Department of Justice, argued the cause for the United States, as amicus curiae, by special leave of court
James L. DeAno - Argued the cause for the petitioners
John R. Wimmer - Argued the cause for the respondent

Facts of the case

Grace Olech asked the Village of Willowbrook to connect her property to the municipal water supply. The Village conditioned the connection on Olech's granting of a 33-foot easement. Olech refused, claiming that the Village only required a 15-foot easement from other property owners seeking access to the water supply. Olech sued the Village claiming that the Village's demand of an additional 18-foot easement violated the Equal Protection Clause of the Fourteenth Amendment. The District Court dismissed the case for failure to state a cognizable claim under the Equal Protection Clause. In reversing, the Court of Appeals held that a plaintiff can allege an equal protection violation by asserting that state action was motivated solely by a "spiteful effort to 'get' him for reasons wholly unrelated to any legitimate state objective."

Question

Does the Equal Protection Clause give rise to a cause of action on behalf of a "class of one" where the plaintiff did not allege membership in a class or group?

Media for Village of Willowbrook v. Olechon

Audio Transcription for Oral Argument - January 10, 2000 in Village of Willowbrook v. Olechon

Audio Transcription for Opinion Announcement - February 23, 2000 in Village of Willowbrook v. Olechon

William H. Rehnquist:

I have the opinion of the Court to announce in No. 98-1288 the Village of Willowbrook v. Grace Olech.

In this case Olech sued the petitioner, the Village of Willowbrook alleging that the Village violated the Equal Protection Clause of the Fourteenth Amendment by demanding a 33-foot easement from her before connecting her property to the municipal water supply instead of the 15-foot easement required from other property owners.

The District Court dismissed the suit for failing to state an Equal Protection Claim.

The Court of Appeals for the Seventh Circuit reversed.

In a per curiam opinion filed with the Clerk today we affirm.

Our cases have recognized that a plaintiff raises valid Equal Protection Claim, when she alleges that she has been intentionally treated differently from others in the similar situation, and there is no rational basis for the difference in treatment.

Olech’s complaint alleged that the Village intentionally demanded an excessive easement from her and that the Village’s demand was irrational and wholly arbitrary.

This is sufficient to state a claim for relief under the Equal Protection Clause.

Justice Breyer has filed an opinion concurring in the judgment.