Geinosky v. City of Chicago

Dist. Ct. erred in granting defendants-police official's motion for summary judgment in plaintiff's section 1983 action alleging under "class-of-one" theory that defendants violated plaintiff's equal protection rights by issuing series of 24 bogus parking tickets. While Dist. Ct. found that plaintiff failed to state cause of action because he neglected to identify similarly situated individuals who had not been subjected to alleged harassment, Ct. of Appeals held that plaintiff's general allegation that defendants intentionally treated him differently than others was sufficient where alleged facts suggested harassment by public officials that had no conceivable legitimate purpose. Dist. Ct. did not err, though, in dismissing plaintiff's similar substantive due process claim where alleged conduct of issuing bogus traffic tickets was insufficient to constitute deprivation that "shocks the conscience" for purposes of due process cases.