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8 California opinions name it 3 courts 2013–2025 2 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Las Lomas Land Company, LLC v. City of Los Angelesgreen2 sentences2018"To succeed on a class of one claim, a plaintiff must establish that '(1) the plaintiff was treated differently from other similarly situated persons, (2) the difference in treatment was intentional, and (3) there was no rational basis for the difference in treatment.' " ( Gerawan Farming, Inc. v. Agricultural Labor Relations Bd. (2017) 3 Cal.5th 1118 , 1144, 225 Cal.Rptr.3d 517 , 405 P.3d 1087 .) The third element is essentially the same rational basis test that courts typically apply in equal protection cases involving economic regulations. ( Las Lomas, supra , 177 Cal.App.4th at p. 858 , 99 2018"To succeed on a class of one claim, a plaintiff must establish that '(1) the plaintiff was treated differently from other similarly situated persons, (2) the difference in treatment was intentional, and (3) there was no rational basis for the difference in treatment.' " ( Gerawan Farming, Inc. v. Agricultural Labor Relations Bd. (2017) 3 Cal.5th 1118 , 1144, 225 Cal.Rptr.3d 517 , 405 P.3d 1087 .) The third element is essentially the same rational basis test that courts typically apply in equal protection cases involving economic regulations. ( Las Lomas, supra , 177 Cal.App.4th at p. 858 , 99 | 3 | 7 |
Gerawan Farming, Inc. v. Agricultural Labor Relations Boardgreen2 sentences2025The United States Supreme Court in Village of Willowbrook v. Olech (2000) 528 U.S. 562 , 564 . . ., however, held that a plaintiff who does not allege membership in a class or group may state 22 a claim as a “ ‘class of one.’ ” ’ ” (California Resources Production Corp. v. Antioch City Council (2025) 107 Cal.App.5th 481 , 489–490.) “To succeed on a class of one claim, a plaintiff must establish that ‘(1) the plaintiff was treated differently from other similarly situated persons, (2) the difference in treatment was intentional, and (3) there was no rational basis for the difference in treatmen 2024(See Gerawan Farming, Inc. v. Agricultural Labor Relations Bd. (2017) 3 Cal.5th 1118, 1142 (Gerawan) 10 [summarizing Olech]; see also Engquist v. Oregon Dept. of Agriculture (2008) 553 U.S. 591, 601 [“we recognized in Olech that an equal protection claim can in some circumstances be sustained even if the plaintiff has not alleged class-based discrimination, but instead claims that she has been irrationally singled out as a so-called ‘class of one’ ”].) A class of one claim requires showing (1) the plaintiff was treated differently from others similarly situated, (2) the different treatment was | 1 | 4 |
Engquist v. Oregon Department of Agriculturegreen2 sentences2024(See Gerawan Farming, Inc. v. Agricultural Labor Relations Bd. (2017) 3 Cal.5th 1118, 1142 (Gerawan) 10 [summarizing Olech]; see also Engquist v. Oregon Dept. of Agriculture (2008) 553 U.S. 591, 601 [“we recognized in Olech that an equal protection claim can in some circumstances be sustained even if the plaintiff has not alleged class-based discrimination, but instead claims that she has been irrationally singled out as a so-called ‘class of one’ ”].) A class of one claim requires showing (1) the plaintiff was treated differently from others similarly situated, (2) the different treatment was 2017In such situations, allowing a challenge based on the arbitrary singling out of a particular person would undermine the very discretion that such state officials are entrusted to exercise." ( Id. at p. 603, 128 S.Ct. 2146 .) Although Engquist 's holding was limited to the public employment context, our Courts of Appeal have concluded that "its reasoning applies more broadly." ( Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837 , 859, 99 Cal.Rptr.3d 503 ( Las Lomas ); see Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 595, 180 Cal.Rptr.3d 10 ["individualized disc | 1 | 2 |
Squires v. City of Eureka CA/2green2 sentences2024This is particularly problematic given the level of similarity between the plaintiff and the comparators for a class of one claim must be “extremely high.” (Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 594–595; see also SmileDirectClub, LLC v. Tippins (9th Cir. 2022) 31 F.4th 1110, 1123 [a “class-of-one plaintiff must be similarly situated to the proposed comparator in all material respects”].) Sparks notes he included the following supporting allegation in his complaint: “If any unvaccinated students could attend class safely in person, then all unvaccinated students should have bee 2017In such situations, allowing a challenge based on the arbitrary singling out of a particular person would undermine the very discretion that such state officials are entrusted to exercise." ( Id. at p. 603, 128 S.Ct. 2146 .) Although Engquist 's holding was limited to the public employment context, our Courts of Appeal have concluded that "its reasoning applies more broadly." ( Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837 , 859, 99 Cal.Rptr.3d 503 ( Las Lomas ); see Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 595, 180 Cal.Rptr.3d 10 ["individualized disc | 1 | 2 |
Jeffrey Sulitzer v. Joseph Tippinsgreen1 sentence2024This is particularly problematic given the level of similarity between the plaintiff and the comparators for a class of one claim must be “extremely high.” (Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 594–595; see also SmileDirectClub, LLC v. Tippins (9th Cir. 2022) 31 F.4th 1110, 1123 [a “class-of-one plaintiff must be similarly situated to the proposed comparator in all material respects”].) Sparks notes he included the following supporting allegation in his complaint: “If any unvaccinated students could attend class safely in person, then all unvaccinated students should have bee | 1 | 1 |
Robert Charles Towery v Janice K Brewergreen1 sentence2017In such situations, allowing a challenge based on the arbitrary singling out of a particular person would undermine the very discretion that such state officials are entrusted to exercise." ( Id. at p. 603, 128 S.Ct. 2146 .) Although Engquist 's holding was limited to the public employment context, our Courts of Appeal have concluded that "its reasoning applies more broadly." ( Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837 , 859, 99 Cal.Rptr.3d 503 ( Las Lomas ); see Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 595, 180 Cal.Rptr.3d 10 ["individualized disc | 1 | 1 |
Analytical Diagnostic Labs, Inc. v. Kuselgreen1 sentence2017In such situations, allowing a challenge based on the arbitrary singling out of a particular person would undermine the very discretion that such state officials are entrusted to exercise." ( Id. at p. 603, 128 S.Ct. 2146 .) Although Engquist 's holding was limited to the public employment context, our Courts of Appeal have concluded that "its reasoning applies more broadly." ( Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837 , 859, 99 Cal.Rptr.3d 503 ( Las Lomas ); see Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 595, 180 Cal.Rptr.3d 10 ["individualized disc | 1 | 1 |
Hanes v. Zurickgreen1 sentence2017In such situations, allowing a challenge based on the arbitrary singling out of a particular person would undermine the very discretion that such state officials are entrusted to exercise." ( Id. at p. 603, 128 S.Ct. 2146 .) Although Engquist 's holding was limited to the public employment context, our Courts of Appeal have concluded that "its reasoning applies more broadly." ( Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837 , 859, 99 Cal.Rptr.3d 503 ( Las Lomas ); see Squires v. City of Eureka (2014) 231 Cal.App.4th 577 , 595, 180 Cal.Rptr.3d 10 ["individualized disc | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Village of Willowbrook v. Olech
green
2 sentences2025The United States Supreme Court in Village of Willowbrook v. Olech (2000) 528 U.S. 562 , 564 . . ., however, held that a plaintiff who does not allege membership in a class or group may state 22 a claim as a “ ‘class of one.’ ” ’ ” (California Resources Production Corp. v. Antioch City Council (2025) 107 Cal.App.5th 481 , 489–490.) “To succeed on a class of one claim, a plaintiff must establish that ‘(1) the plaintiff was treated differently from other similarly situated persons, (2) the difference in treatment was intentional, and (3) there was no rational basis for the difference in treatmen 2017To succeed on a class of one claim, a plaintiff must establish that "(1) the plaintiff was treated differently from other similarly situated persons, (2) the difference in treatment was intentional, and (3) there was no rational basis for the difference in treatment." ( Las Lomas , supra , 177 Cal.App.4th at p. 858 , 99 Cal.Rptr.3d 503 , citing Olech , supra , 528 U.S. at p. 564 , 120 S.Ct. 1073 .) There is no question that differences in treatment among agricultural employers under the MMC statute is "intentional" ( Las Lomas , at p. 858, 99 Cal.Rptr.3d 503 ), since the point of the scheme is | 3 | 2013–2025 |
Wachs v. Curry
green
2 sentences2018Where the defendant is "the party moving for summary judgment[,] it has the burden of negating a necessary element of the plaintiff's case or establishing an affirmative defense. [Citation.] In the area of economic regulation, a legislative classification does not deny equal protection if the 'distinctions drawn by a challenged [act] bear some rational relationship to a conceivable legitimate state purpose.' [Citation.] Thus, in a case where the state moves for summary judgment, the state meets its burden by demonstrating some conceivably rational basis for its classification. 'A distinction . 2018Where the defendant is "the party moving for summary judgment[,] it has the burden of negating a necessary element of the plaintiff's case or establishing an affirmative defense. [Citation.] In the area of economic regulation, a legislative classification does not deny equal protection if the 'distinctions drawn by a challenged [act] bear some rational relationship to a conceivable legitimate state purpose.' [Citation.] Thus, in a case where the state moves for summary judgment, the state meets its burden by demonstrating some conceivably rational basis for its classification. 'A distinction . | 1 | 2018–2018 |
Marathon Entertainment, Inc. v. Blasi
green
2 sentences2018Where the defendant is "the party moving for summary judgment[,] it has the burden of negating a necessary element of the plaintiff's case or establishing an affirmative defense. [Citation.] In the area of economic regulation, a legislative classification does not deny equal protection if the 'distinctions drawn by a challenged [act] bear some rational relationship to a conceivable legitimate state purpose.' [Citation.] Thus, in a case where the state moves for summary judgment, the state meets its burden by demonstrating some conceivably rational basis for its classification. 'A distinction . 2018Where the defendant is "the party moving for summary judgment[,] it has the burden of negating a necessary element of the plaintiff's case or establishing an affirmative defense. [Citation.] In the area of economic regulation, a legislative classification does not deny equal protection if the 'distinctions drawn by a challenged [act] bear some rational relationship to a conceivable legitimate state purpose.' [Citation.] Thus, in a case where the state moves for summary judgment, the state meets its burden by demonstrating some conceivably rational basis for its classification. 'A distinction . | 1 | 2018–2018 |
SYNGENTA CORP PROTECTION, INC. v. Helliker
green
1 sentence2013(Syngenta Crop Protection, Inc. v. Helliker (2006) 138 Cal.App.4th 1135, 1174 .) I.F.’s equal protection claim fails because there is no evidence the failure to provide him with his ADHD medication was intentional or purposeful. | 1 | 2013–2013 |
City of Cleburne v. Cleburne Living Center, Inc.
green
1 sentence2013(Cleburne v. Cleburne Living Center, Inc. (1985) 473 U.S. 432, 439 ; Las Lomas Land Co., LLC v. City of Los Angeles (2009) 177 Cal.App.4th 837, 857 .) The constitutional right to equal protection applies not only to groups, but to individuals who constitute a “‘class of one’” (Village of Willowbrook v. Olech (2000) 528 U.S. 562, 564 ) if the individual “has been intentionally treated differently from others similarly situated and … there is no rational basis for the difference in treatment.” (Ibid.) To prove a class-of-one claim under the federal or state Constitution, it must be established t | 1 | 2013–2013 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.