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Engquist v. Oregon Department of Agriculture

Supreme Court of the United States · 2008 · Constitutional Law

Constitutional LawEqual ProtectionPublic EmploymentEqual Protection Clauseclass of onepublic employmentgovernment as employersubjective personnel decisions

Facts

Anup Engquist worked for a laboratory within the Oregon Department of Agriculture and had recurring conflicts with coworker Joseph Hyatt. After John Szczepanski assumed supervisory authority, he selected Hyatt over Engquist for a managerial post, eliminated Engquist's supervisor's position during budget cuts, and later informed Engquist that her own position was being eliminated due to reorganization. Engquist alleged not only discrimination based on race, sex, and national origin, but also that she had been singled out and fired for arbitrary, vindictive, and malicious reasons. The jury rejected her class-based discrimination claims but found for her on the class-of-one equal protection claim.

Issue

Can a public employee state an Equal Protection Clause claim under a class-of-one theory by alleging that she was arbitrarily treated differently from other similarly situated employees, without alleging discrimination based on membership in any particular class? More specifically, does the class-of-one theory recognized in Olech apply to individualized public employment decisions?

Rule

A class-of-one equal protection claim has no place in the public employment context. Although the Equal Protection Clause applies to public employers and still prohibits class-based discrimination in employment, it does not authorize claims based solely on allegedly arbitrary differential treatment arising from individualized, subjective personnel decisions.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Alvarez works as a budget analyst for the City of Denver. After clashing with her supervisor, she is denied a transfer that three coworkers with similar experience receive, and she alleges the supervisor acted out of pure spite rather than because of race, sex, or any other group-based characteristic.

If Nina sues under the Equal Protection Clause on a class-of-one theory, what is the strongest argument for dismissal?

Explanation. The majority held that class-of-one equal protection claims have no place in the public employment context when the challenged act is an individualized, subjective personnel decision. Even if the employee alleges arbitrary, vindictive, or malicious treatment compared with similarly situated coworkers, that theory is barred unless the employee alleges class-based discrimination.