100 F.4th 814
7th Cir.2024Background
- Greenwald Family Limited Partnership (Partnership) owns undeveloped land in Mukwonago, Wisconsin, and had a positive development relationship with the Village until around 2014.
- The relationship soured after the Partnership’s failed purchase of part of the Chapman Farms property, which was conditioned on municipal approvals and required infrastructure commitments the Partnership did not meet.
- Additional friction arose when the Village rerouted a planned road (DeBack Drive/Wolf Run Extension) away from the Partnership’s property, favoring a more efficient and economically sound route.
- The Partnership filed suit, asserting a “class of one” Equal Protection claim, alleging it was irrationally singled out for unfavorable treatment by the Village.
- The district court granted summary judgment for the Village, ruling that all adverse actions had a rational basis related to land-use objectives and fiscal concerns.
- The Seventh Circuit affirmed the district court’s judgment, holding the Partnership failed to prove the Village acted without any rational basis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rationality of Village’s actions (Chapman Farms) | Village imposed arbitrary requirements, treating Partnership differently | Requirements were rational, related to infrastructure and community planning needs | Village's actions were rational, not unconstitutional |
| Road rerouting (DeBack Drive) | Village favored other developers, harming Partnership’s land value/use | Chose cost-effective, practical road placement for public benefit | Decision had rational basis, rejected class-of-one claim |
| Additional municipal decisions (other disputes) | Village repeatedly singled out Partnership for adverse treatment | Adverse actions based on lawful, rational land-use and finance considerations | All challenged acts justified by rational municipal aims |
| Role of personal animus/intent | Emails reveal animus; motivated actions against Partnership | Motive irrelevant if rational basis exists for actions | Rational basis found; motive irrelevant to outcome |
Key Cases Cited
- Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (sets out the class-of-one equal protection claim standard)
- James v. Hale, 959 F.3d 307 (7th Cir. 2020) (summary judgment deference and standards in equal protection context)
- Miller v. City of Monona, 784 F.3d 1113 (7th Cir. 2015) (plaintiff must negate any conceivable rational basis in class-of-one claims)
- 145 Fisk, LLC v. Nicklas, 986 F.3d 759 (7th Cir. 2021) (any reasonably conceivable rational basis suffices for constitutional review)
- Srail v. Village of Lisle, 588 F.3d 940 (7th Cir. 2009) (municipal cost concerns as rational basis in land use decisions)