Reaffirming the High Bar for “Class-of-One” Equal-Protection Claims in the Sex-Offender Registration Context:
Flynt J. Lee v. Perez Stanford, No. 24-2417 (7th Cir. July 10, 2025)

1. Introduction

This non-precedential decision from the United States Court of Appeals for the Seventh Circuit revisits two recurring themes in federal civil-rights litigation:

• the immunity of state agencies and their officials under 42 U.S.C. § 1983, and
• the demanding pleading standard governing “class-of-one” equal-protection claims, particularly when the plaintiff alleges only a single instance of differential treatment.

Parties. Plaintiff-appellant Flynt (Flint) J. Lee, an Illinois sex-offender registrant, sued (i) the Illinois State Police; (ii) the Chicago Police Department Registration Division; and (iii) Officer Perez Stanford, a Chicago Police officer who allegedly denied him an application to waive the statutory $100 registration fee. Lee pursued damages under § 1983, alleging violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Core Dispute. Lee contended that Officer Stanford’s single refusal to hand over a fee-waiver form—conduct he characterized as irrational and intentional—caused his subsequent arrest for failure to register. The district court dismissed the suit, and the Seventh Circuit has now affirmed.

2. Summary of the Judgment

1. The Illinois State Police cannot be sued for damages under § 1983 because a state agency is not a “person” within the statute’s meaning (Will v. Michigan Dep’t of State Police).
2. Lee’s attempt to name additional individuals (e.g., the head of the State Police Registration Unit) on appeal was rejected; parties must be added, if at all, in the trial court.
3. Lee failed to state an equal-protection “class-of-one” claim: a single episode where an officer refused a form, without plausible facts indicating intentional, irrational discrimination, does not meet Iqbal/Twombly pleading standards.
4. Procedural and substantive due-process theories also failed:—(a) no protected liberty interest exists in registering as a sex offender, and (b) the conduct alleged does not “shock the conscience.”
5. The judgment of dismissal was therefore affirmed.

3. Analysis

3.1 Precedents Cited and Their Influence

• Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989)
  Established that neither states nor their agencies are “persons” for § 1983 damages suits. The panel relied on Will to dispose of Lee’s claims against the Illinois State Police without reaching Eleventh-Amendment immunity.
• Village of Willowbrook v. Olech, 528 U.S. 562 (2000)
  Articulated the modern “class-of-one” equal-protection test: (i) intentional differential treatment compared with similarly situated persons, and (ii) absence of a rational basis. The Seventh Circuit found Lee pleaded only conclusory labels, not facts establishing either prong.
• Ashcroft v. Iqbal, 556 U.S. 662 (2009) & Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)
• Require “plausible” factual allegations, not mere legal conclusions. The court treated Lee’s words “arbitrary,” “intentional,” and “no rational basis” as conclusory.
• Frederickson v. Landeros, 943 F.3d 1054 (7th Cir. 2019)
  Demonstrates when a class-of-one claim survives—plaintiff alleged repeated, targeted conduct with a plausible motive. The panel contrasted that case with Lee’s solitary interaction with Officer Stanford.
• Geinosky v. City of Chicago, 675 F.3d 743 (7th Cir. 2012)
  Explained how a pattern (24 bogus parking tickets) can convert suspicion into plausibility; again contrasted with Lee’s single incident.
• Younger v. Harris, 401 U.S. 37 (1971)
  Cited to explain the district court’s temporary stay while state criminal proceedings were pending.
• Additional authorities—Greenwald Family Ltd. Partnership v. Mukwonago, FKFJ, Inc. v. Village of Worth, Del Marcelle v. Brown County Corp., Snowden v. Hughes, Thiele v. Board of Trustees, and others—reinforce the unsettled yet rigorous requirements for class-of-one claims and clarify that violations of state law do not automatically equal constitutional violations.

3.2 The Court’s Legal Reasoning

The panel’s reasoning proceeded along three logical tracks:

1. Statutory Predicate (Who May Be Sued). The court began with the threshold question whether the Illinois State Police is a suable “person.” Under Will, the answer is no, obviating any Eleventh-Amendment analysis.
2. Pleading Sufficiency for the Class-of-One Claim.
   • The court assumed, arguendo, that Lee’s most detailed allegations (found in the second amended complaint) were before it.
   • Nevertheless, factual content was missing: Lee alleged only a one-time refusal, with no context showing personal animus, a pattern of denial, or differential treatment compared with similarly situated registrants.
   • Without more, the allegation is as consistent with mistake or bureaucratic ineptitude as with intentional discrimination, and therefore fails under Iqbal/Twombly.
3. Failure of Due-Process Theories.
   • Procedural Due Process: No protected liberty/property interest in being allowed to register without paying the fee.
   • Substantive Due Process: Refusal to hand over a form does not “shock the conscience.”

3.3 Impact of the Decision

While labeled “nonprecedential,” the opinion offers practical guidance:

• Pleading Strategy. Litigants alleging class-of-one theories must provide concrete facts—patterns, motives, comparators, or documented animus— to survive dismissal.
• Institutional Targets. Plaintiffs cannot obtain damages from state agencies under § 1983. Counsel must sue individual officers in their personal capacities and allege personal involvement.
• Sex-Offender Registration Litigation. Claims premised solely on local mishandling of registration paperwork will rarely yield constitutional relief absent systemic, intentional discrimination.
• Judicial Economy. The panel’s willingness to affirm on “not-a-person” grounds, without wading into Eleventh-Amendment immunity, underscores the court’s preference for resolving cases on narrow, non-constitutional grounds when possible (constitutional avoidance doctrine).

4. Complex Concepts Simplified

• § 1983 “Person.” Only individuals (and certain entities like municipalities) can be sued for damages under § 1983. States and their agencies are excluded.
• Eleventh-Amendment Immunity. Even if a state agency were a “person,” it is presumptively immune from suits for money damages in federal court unless it expressly waives immunity or Congress validly abrogates it.
• Class-of-One Equal Protection. Instead of alleging discrimination based on race, gender, etc., a plaintiff claims he alone was singled out irrationally. Courts insist on robust facts showing intentional targeting without reason.
• Iqbal/Twombly Standard. Complaints must contain sufficient factual matter to make liability plausible, not merely possible. Labels and conclusions do not suffice.
• Younger Abstention. Federal courts generally abstain from interfering with ongoing state criminal proceedings, pausing civil suits until the state case ends.
• Procedural vs. Substantive Due Process.
  • Procedural: Focuses on the process owed before depriving someone of life, liberty, or property.
  • Substantive: Prohibits certain government actions regardless of process when they are arbitrary, oppressive, or “shock the conscience.”

5. Conclusion

Flynt Lee v. Perez Stanford reiterates two practical teachings for § 1983 litigants in the Seventh Circuit. First, state agencies are non-suable entities under the statute; plaintiffs should focus on individual actors. Second, a class-of-one equal-protection claim demands more than a lone instance of official misfeasance plus conclusory buzzwords. Absent factual allegations showing a pattern of differential treatment, a plausible improper motive, or identified comparators, such claims will quickly founder on the shoals of Iqbal/Twombly. Though technically non-precedential, the opinion supplies a clear roadmap for district courts confronting similar complaints and cautions would-be plaintiffs to plead facts—not labels—when alleging constitutional wrongs arising from mundane administrative encounters.