Friday, November 29, 2013

Village of Willowbrook v. Olech

Village of Willowbrook v. Olech case brief summary
528 U.S. 562 (2000)

Certiorari was granted to the United States Court of Appeals for the Seventh Circuit, which reversed the dismissal of a suit filed by respondent homeowner against petitioner municipality, on the grounds that the homeowner alleged a cognizable claim under the Equal Protection Clause of the Fourteenth Amendment.

The homeowner's complaint alleged that the municipality demanded a 33-foot easement as a condition of connecting her property to the municipal water line, whereas only a 15-foot easement was required from other property owners in her subdivision. Further, she claimed that the municipality's demand for additional footage was irrational and wholly arbitrary and that the homeowner ultimately connected her property after receiving a clearly adequate 15-foot easement. The district court dismissed the lawsuit pursuant to Fed. R. Civ. P. 12(b)(6)for failure to state a cognizable claim under the Equal Protection Clause.

  • The appellate court reversed, holding that a plaintiff could 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. 
  • On certiorari, the Court held that, although the homeowner constituted a class of one member, she had successfully stated a cognizable equal protection claim, so the Court was not required to determine whether the municipality's retaliation for the homeowner's previous unrelated lawsuit presented an equal protection violation.
The Court affirmed the appellate court judgment reversing the dismissal of the homeowner's suit.

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