Village of Willowbrook v. Olech

Brief Fact Summary. The Village of WillowBrook stated they need a 33 ft easement in order to give water to the Olechs when everyone else only needed to grant a 15 foot easement.

Synopsis of Rule of Law. A state must have a rational basis for its actions even as against a class of one person.

Facts. The Olechs asked the Village to connect them to the municipal water supply. The Village requested a 33 foot easement to make the connection. Everyone else only had to grant a 15 foot easement. The Olechs believe this decision was made because the Olechs had previous won another suit against the Village and ill will was the basis for its decision. The Olechs refused and the Village eventually agreed to supply the water with only a 15 foot easement, 

Issue. Whether the Equal Protection Clause gives rise to a cause of action for a class of one.

Held. Yes. It has been held previously that when an individual has been intentionally treated differently from other similarly situated and that there is no rational basis for that different there has been a violation of the equal protection clause. Every person should be secured against intentional and arbitrary discrimination. The town was able to connect the Olechs to water with a 15 foot easement and there actions where the result of discrimination.

Dissent.  

Discussion. There is no need to find subjective ill will to find a states action to be intentional or arbitrary.