Engquist v. Oregon Department of Agriculture

Background

Anup Engquist was an Oregon public employee who sued her state agency, her supervisor, and a co-worker after she lost a managerial promotion and then was laid off. She alleged discrimination for race, sex, and national origin, and also a "class-of-one" claim, saying she was singled out for arbitrary, vindictive treatment rather than because she belonged to a group. A jury found for her on the class-of-one claim, awarded damages, but the Ninth Circuit reversed that theory for public employment before the case reached the Supreme Court.

Reasoning

The Court considered whether the Equal Protection Clause allows an employee to sue simply for being treated differently from other employees without alleging class-based discrimination. The majority said no. It explained that government acts differently when it regulates the public than when it manages its own workforce. Employment decisions are often subjective and individualized, relying on personality, efficiency, and internal needs. Allowing class-of-one claims would turn routine personnel choices into constitutional lawsuits and would conflict with at-will employment traditions and managerial discretion.

Real world impact

The ruling prevents most class-of-one equal protection suits against public employers, making it harder for individual employees to rely on the Constitution to challenge alleged arbitrary firings, promotions, or assignments. It leaves intact other legal protections, including claims based on membership in a protected group and statutory or contractual remedies. The decision says it does not excuse unconstitutional class-based employment actions but limits one constitutional path for relief.

Dissents or concurrances

Justice Stevens, joined by two Justices, dissented, arguing that Olech permits class-of-one claims when there is no rational basis for the discrimination and that the Court should not carve out public employees from that protection.