Village Of Willowbrook v. Olech

528 U.S. 562 (2000)

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Nature of the Case

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Facts

P asked D to connect their property to the municipal water supply. D conditioned the connection on P granting D a 33-foot easement. P objected, claiming that D only required a 15-foot easement from other property owners seeking access to the water supply. After a 3-month delay, the Village relented and agreed to provide water service with only a 15-foot easement. P sued D claiming that the demand of an additional 18-foot easement violated the Equal Protection Clause of the Fourteenth Amendment. P claimed that the 33-foot easement demand was 'irrational and wholly arbitrary'; D's demand was actually motivated by ill will resulting from P's previous filing of an unrelated, successful lawsuit against D; and that D acted either with the intent to deprive P of her rights or in reckless disregard of her rights. The District Court dismissed pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a cognizable claim under the Equal Protection Clause. The Seventh Circuit reversed, holding 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.'' The Supreme Court granted certiorari to determine whether the Equal Protection Clause gives 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.