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Keywords

lawsuitdefendantdamagesattorneyappealdue process

plaintiffdefendantdamagesappealmotiondue process

Related Cases

Engquist v. Oregon Dept. of Agriculture, 478 F.3d 985, 90 Empl. Prac. Dec. P 43,066, 154 Lab.Cas. P 60,357, 25 IER Cases 1025, 72 Fed. R. Evid. Serv. 483, 07 Cal. Daily Op. Serv. 1411, 32 A.L.R.6th 795

Facts

Engquist was hired by the Oregon Department of Agriculture in 1992 and faced ongoing issues with her colleague Hyatt, who was accused of excessive monitoring and making false statements about her. After a series of events, including a budget crisis and a reorganization led by Szczepanski, Engquist's position was eliminated in January 2002. Despite applying for numerous jobs, she struggled to find employment in her field, leading to her lawsuit against the department and individual defendants for various claims.

Engquist was hired in 1992 as an international food standards specialist for the Export Service Center (“ESC”), a laboratory in the ODA. She was hired by Norma Corristan (“Corristan”), who was the director of the ODA's Laboratory Services Division (“LSD”), which included the ESC.

Issue

The main legal issues included whether the class-of-one theory of equal protection applies to public employment decisions and whether Engquist's substantive due process rights were violated.

The jury concluded that Defendants were liable on the equal protection claim because Defendants “intentionally treat[ed] the plaintiff differently than others similarly situated with respect to the denial of her promotion, termination of her employment, or denial of bumping rights without any rational basis and solely for arbitrary, vindictive, or malicious reasons.”

Rule

The court held that the class-of-one theory of equal protection is inapplicable to public employment decisions and that substantive due process protections exist against government employer actions that restrict access to a profession.

We hold that the class-of-one theory of equal protection is not applicable to decisions made by public employers.

Analysis

The court determined that Engquist's claims under the class-of-one theory were invalid as a matter of law, emphasizing that public employers have broader powers than the government as a regulator. Additionally, while recognizing a substantive due process right to pursue a profession, the court found that Engquist did not provide sufficient evidence to demonstrate that the defendants' actions directly caused her inability to find employment.

The court determined that Engquist's claims under the class-of-one theory were invalid as a matter of law, emphasizing that public employers have broader powers than the government as a regulator.

Conclusion

The Court of Appeals reversed the judgment in favor of Engquist on her constitutional claims, vacated the damages and attorney fees awarded, and remanded the case for adjustments.

Accordingly, we hold that Engquist has stated a valid claim—a claim upon which relief can be granted—under substantive due process by alleging that Defendants' actions prevented her from pursuing her profession.

Who won?

The prevailing party was the defendants, as the Court of Appeals reversed the judgment in favor of Engquist on her constitutional claims, leading to the vacating of damages.

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