Systematic Recycling LLC v. City of Detroit, 635 F. App'x 175

Detroit granted Systematic a conditional land use permit for a 10-acre composting facility in Delray, conditioned on an existing Host Community Agreement (HCA).
The HCA was executed in March 2007 and could terminate if not renewed by March 2009; renewal was essential to continue operation.
Rosendall, owner related to the property, pled guilty in 2009 to bribing Detroit officials to obtain the HCA; Systematic allegedly benefited from the tainted process.
In March 2009 Detroit decided not to renew the HCA, citing the fraud in obtaining it, and effectively allowed the permit to lapse, prompting Systematic to seek relief.
Systematic sued in federal court asserting §1983 claims for due process, equal protection, and First Amendment retaliation, plus unjust enrichment; district court granted summary judgment for Detroit.
On appeal, the Sixth Circuit affirmed the district court's grant of summary judgment, finding no triable issues on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Detroit’s nonrenewal of the HCA and revocation of the permit violated substantive due process or equal protection.	Systematic contends Detroit acted irrationally due to fraud in obtaining the HCA.	Detroit had a rational basis to not renew the HCA given the bribery history and to revoke the permit.	No genuine issue; decisions grounded in rational basis given fraud.
Whether Detroit’s nonrenewal of the HCA violated equal protection under a class-of-one theory.	Systematic was treated differently from similarly situated entities without rational basis.	Detroit's action targeted fraud and did not single out Systematic without rational basis.	No class-of-one violation; rational basis supported.
Whether Detroit's revocation of the permit violated procedural due process.	Systematic lacked meaningful process in revocation.	De novo review by the Board allowed new evidence and meaningful opportunity to be heard.	Procedural due process satisfied; no violation.
Whether Detroit’s actions violated Systematic’s First Amendment right to petition.	Detroit retaliated against Systematic for filing suit seeking due process protections.	No causal link; revocation preceded Systematic’s petition rights, and actions were to provide due process.	No First Amendment retaliation; no causal connection.

Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (equal protection class-of-one rational basis standard)
Engquist v. Oregon Dept. of Agric., 553 U.S. 591 (2008) (limits on class-of-one claims in public employment)
FCC v. Beach Communications, Inc., 508 U.S. 307 (1993) (rational basis review; any conceivable basis suffices)
Warren v. City of Athens, 411 F.3d 697 (2005) (class-of-one rational-basis framework in this circuit)
Mass. Bd. of Ret. v. Murgia, 427 U.S. 307 (1976) (rational basis review; policy judgments upheld if plausible)
Brody v. City of Mason, 250 F.3d 432 (2001) (substantive due process in zoning; arbitrary and capricious standard)
Hussein v. City of Perrysburg, 617 F.3d 828 (2010) (zoning decisions and due process under rational basis)
Thaddeus-X v. Blatter, 175 F.3d 378 (1999) (First Amendment retaliation standard for petsitions and lawsuits)
Triomphe Investors v. City of Northwood, 49 F.3d 198 (1995) (zoning appeals de novo review and evidentiary considerations)