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Constitutional Law Keyed to Choper
Engquist v. Oregon Dept. of Agriculture
Citation:
553 U.S. 591 (2008)Facts
Anup Engquist was hired in 1992 as an international food standard specialist for the Oregon Department of Agriculture. She experienced ongoing problems with co-worker Joseph Hyatt and complained to her supervisor. In 2001, John Szczepanski became her supervisor and allegedly told a client he would “get rid of” Engquist. When both Engquist and Hyatt applied for a managerial position, Szczepanski selected Hyatt despite Engquist’s greater experience. During budget cuts, Engquist’s position was eliminated. She was found unqualified for the only other position at her level, declined a demotion, and was effectively laid off. Engquist sued, alleging discrimination based on race, sex, and national origin, as well as a “class-of-one” equal protection claim, asserting she was treated differently from others similarly situated for arbitrary and malicious reasons. The jury rejected her class-based discrimination claims but found in her favor on the class-of-one claim, determining that defendants intentionally treated her differently without any rational basis.
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