Engquist v. Oregon Dept. of Agriculture, 553 U.S. 591 (2008)

Anup Engquist was hired in 1992 by the Oregon Department of Agriculture (ODA) as an international food standard specialist. During her tenure, she faced ongoing issues with a colleague, Joseph Hyatt, whom she accused of making false statements about her and creating a hostile work environment. After a change in supervision when John Szczepanski became the assistant director of ODA, he expressed a lack of control over Engquist and indicated a desire to eliminate both her and her supervisor, Norma Corristan. When Engquist and Hyatt both applied for a managerial position, Szczepanski chose Hyatt despite Engquist's superior qualifications. Subsequently, during budget cuts, Corristan's position was eliminated, and Engquist was informed that her position would also be terminated due to reorganization. She was unable to secure another position at her level and declined a demotion, leading to her effective layoff. Engquist initiated legal action against the ODA, Szczepanski, and Hyatt in the United States District Court for the District of Oregon, claiming violations of federal antidiscrimination statutes, the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and state law. Among her allegations, Engquist asserted a "class-of-one" equal protection claim, contending that her termination was arbitrary and vindictive rather than based on her membership in a specific class. The District Court granted summary judgment on some claims but allowed Engquist's equal protection claims to proceed, including her class-of-one theory, which it deemed legally viable in the employment context. The case eventually reached the Supreme Court on a writ of certiorari to the Ninth Circuit, where the central question was whether a public employee could assert a claim under the Equal Protection Clause based solely on allegations of arbitrary treatment without any connection to class-based discrimination. The Supreme Court ultimately held that the "class-of-one" theory does not apply within the public employment context, thereby addressing the broader implications of equal protection claims in such settings.

Whether a public employee can state a claim under the Equal Protection Clause by alleging arbitrary treatment compared to similarly situated employees without asserting that the different treatment was based on membership in a particular class.

The judgment of the Court of Appeals is affirmed.