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plaintiffappealwilleasementrespondent
plaintiffappealwilleasementrespondent

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Willowbrook v. Olech

Facts

Respondent Grace Olech and her late husband Thaddeus asked petitioner Village of Willowbrook to connect their property to the municipal water supply. The Village at first conditioned the connection on the Olechs granting the Village a 33-foot easement. The Olechs objected, claiming that the Village 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. 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.

Respondent Grace Olech and her late husband Thaddeus asked petitioner Village of Willowbrook to connect their property to the municipal water supply. The Village at first conditioned the connection on the Olechs granting the Village a 33-foot easement. The Olechs objected, claiming that the Village 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. 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.

Issue

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.

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.

Rule

Our cases have recognized successful equal protection claims brought by a 'class of one,' where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment.

Our cases have recognized successful equal protection claims brought by a 'class of one,' where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment.

Analysis

The court applied the rule by determining that Olech's complaint sufficiently alleged that the Village intentionally demanded a 33-foot easement as a condition of connecting her property to the municipal water supply, while requiring only a 15-foot easement from other similarly situated property owners. The court noted that the allegations of irrational and arbitrary treatment were sufficient to state a claim for relief under traditional equal protection analysis.

The court applied the rule by determining that Olech's complaint sufficiently alleged that the Village intentionally demanded a 33-foot easement as a condition of connecting her property to the municipal water supply, while requiring only a 15-foot easement from other similarly situated property owners. The court noted that the allegations of irrational and arbitrary treatment were sufficient to state a claim for relief under traditional equal protection analysis.

Conclusion

The Court affirmed the judgment of the Court of Appeals, but did not reach the alternative theory of 'subjective ill will' relied on by that court.

The Court affirmed the judgment of the Court of Appeals, but did not reach the alternative theory of 'subjective ill will' relied on by that court.

Who won?

The homeowner, Grace Olech, prevailed because the Court found that she had successfully stated a cognizable equal protection claim.

The homeowner, Grace Olech, prevailed because the Court found that she had successfully stated a cognizable equal protection claim.

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