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Village of Willowbrook v. Olech
Village of Willowbrook v. Olech
Village of Willowbrook v. Olech
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. Olech asserted that the 33-foot easement demand was
“irrational and wholly arbitrary”; that the Village’s demand was actually
motivated by ill will resulting from the Olechs’ previous filing of an
unrelated, successful 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 lawsuit pursuant to Federal Rule of Civil
Procedure 12(b)(6) for failure to state a cognizable claim under the Equal
Protection Clause. Relying on Circuit precedent, the Court of Appeals for
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.’”
Issue: Whether or not 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. YES.