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Village of Willowbrook v. Olechon, 528 U.S. 562 (2000)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Village of Willowbrook v. Olechon, 528 U.S. 562 (2000)
Village of Willowbrook v. Olechon No. 98-1288 Decided February 23, 2000 528 U.S. 562
ON WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF APPEALS FOR THE SEVENTH CIRCUIT
Syllabus
When respondent Olech and her late husband first asked petitioner Village of Willowbrook (Village) to connect their property to the municipal water supply, the Village conditioned the connection on the Olechs’ granting it a 33-foot easement. Although it subsequently reduced the easement to the 15 feet required of other property owners, Olech sued, claiming that the Village’s demand for an additional 18-foot easement violated the Fourteenth Amendment’s Equal Protection Clause and asserting that the easement was irrational and arbitrary, that the Village was motivated by ill will resulting from the Olechs’ success in an unrelated lawsuit against the Village, and that the Village acted either with the intent to deprive Olech of her rights or in reckless disregard of her rights. The District Court dismissed the suit for failure to state a claim, but the Seventh Circuit reversed, holding that Olech’s spiteful ill will allegation stated a claim.
Held: the Equal Protection Clause gives rise to a cause of action on behalf of a "class of one" where the plaintiff does not allege membership in a class or group, but alleges that she has been intentionally treated differently from others similary situated and that there is no rational basis for such treatment. See, e.g., Sioux City Bridge Co. v. Dakota County, 260 U.S. 441. The Clause secures every person within a State’s jurisdiction against intentional and arbitrary discrimination, whether occassioned by a statute’s express terms or by its improper execution. Id. at 445. Here, Olech’s allegations that the Village intentionally demanded a 33-foot easement from her when it required only 15 feet from similarly situated property owners, that the demand was irrational and arbitrary, and that the Village ultimately connected her property in return for a 15-foot easement -- quite apart from the Village’s subjective motive -- state a claim for relief under traditional equal protection analysis. Thus, the Court does not reach the alternative "subjective ill will" theory on which the Seventh Circuit relied.
160 F.3d 386 affirmed.
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Chicago: U.S. Supreme Court, "Syllabus," Village of Willowbrook v. Olechon, 528 U.S. 562 (2000) in 528 U.S. 562 528 U.S. 563. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=9WFSMRD1MWP8FCF.
MLA: U.S. Supreme Court. "Syllabus." Village of Willowbrook v. Olechon, 528 U.S. 562 (2000), in 528 U.S. 562, page 528 U.S. 563. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=9WFSMRD1MWP8FCF.
Harvard: U.S. Supreme Court, 'Syllabus' in Village of Willowbrook v. Olechon, 528 U.S. 562 (2000). cited in 2000, 528 U.S. 562, pp.528 U.S. 563. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=9WFSMRD1MWP8FCF.
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