Third Circuit Re-Affirms Stringent Comparator Standard for “Class-of-One” Equal Protection Claims During Municipal Code Enforcement

Charles Jaramillo et al. v. City of Coatesville et al.,
United States Court of Appeals for the Third Circuit, No. 23-2700 (6 Aug 2025) – Not Precedential

Introduction

This appeal arose from a long-running dispute over four commercial and residential parcels on East Lincoln Highway in Coatesville, Pennsylvania. Charles Jaramillo—who claimed ownership rights via a 2015 contract with Maranatha Evangelistic Temple (“Maranatha”)—and six tenant-businesses alleged that the City of Coatesville and various officials violated their constitutional rights when the City ordered occupants to vacate the properties because of code-enforcement concerns.

The primary issues before the Third Circuit were:

Whether the City’s code-enforcement actions constituted a “class-of-one” Equal Protection violation;
Whether the temporary shut-down of the buildings was an unreasonable seizure of property under the Fourth Amendment;
Whether Plaintiffs were denied procedural due process; and
Whether the doctrine of res judicata barred consideration of an affidavit submitted in earlier state-court proceedings.

Summary of the Judgment

The Court of Appeals affirmed summary judgment in favor of the City and the individual defendants. It held:

Maranatha was not a “similarly situated” comparator; therefore, the Equal Protection claim failed at the threshold.
Even if differential treatment had occurred, the City possessed a rational basis—public-safety concerns—to order evacuation.
The temporary loss of possession triggered by safety orders did not amount to an unreasonable seizure.
Dismissal “without prejudice” in prior state litigation eliminated any res judicata effect.
Plaintiffs identified no process that was due yet denied, defeating the procedural due-process claim.

Analysis

1. Precedents Cited

Hill v. Borough of Kutztown, 455 F.3d 225 (3d Cir. 2006)
– Established the modern Third-Circuit test for “class-of-one” Equal Protection claims (intentional differential treatment of similarly situated comparators, without rational basis).
Startzell v. City of Philadelphia, 533 F.3d 183 (3d Cir. 2008)
– Reiterated that comparators must be alike “in all relevant aspects.” The panel relied heavily on this language to exclude Maranatha as a comparator.
Soldal v. Cook County, 506 U.S. 56 (1992)
– Articulated the definition of a “seizure” of property for Fourth Amendment purposes (meaningful interference with possessory interests).
Cinea v. Certo, 84 F.3d 117 (3d Cir. 1996)
– Clarified that an unreasonable seizure, not any seizure, violates the Fourth Amendment.
Venuto v. Witco Corp., 117 F.3d 754 (3d Cir. 1997) & Duhaney v. Attorney General, 621 F.3d 340 (3d Cir. 2010)
– Laid out the elements for res judicata, specifically that a dismissal “without prejudice” is not a final judgment on the merits.
Mulholland v. Government County, 706 F.3d 227 (3d Cir. 2013) & Iles v. de Jongh, 638 F.3d 169 (3d Cir. 2011)
– Defined the two-part test for procedural due-process claims (protected interest + inadequate procedures).
Cranbury Brick Yard, LLC v. United States, 943 F.3d 701 (3d Cir. 2019)
– Recited the de novo standard of review for summary-judgment rulings.

2. Court’s Legal Reasoning

a) Equal Protection (“Class-of-One”)

The panel reiterated that a plaintiff must pinpoint another individual or entity “alike in all relevant aspects.” Owning the same property at different times did not make Maranatha and Jaramillo comparators because the factual triggers of enforcement (heating failure vs. ownership/title dispute + defective fire alarm) were materially different.
Even assuming differential treatment, the City showed a rational basis: life-safety risks. Under rational-basis review, any conceivable legitimate purpose suffices; the Court shall not second-guess municipal risk assessments.

b) Fourth Amendment Seizure

Ordering tenants to vacate constituted a “seizure” in the technical sense (Soldal standard satisfied) but was reasonable because it was narrowly tailored to remediate safety violations and offered a ten-day compliance window.

c) Procedural Due Process

Plaintiffs failed to identify what additional procedures they were entitled to beyond notice of violations and opportunity to cure. As the burden rests with the plaintiff to show inadequate procedures, the claim necessarily failed.

d) Res Judicata Argument

The panel emphasized that an earlier state-court denial of a preliminary injunction without prejudice is not a final judgment; therefore, an affidavit used in that case may be considered in later proceedings.

3. Impact of the Decision

Although the opinion is marked “Not Precedential,” it is persuasive authority within the Third Circuit and may influence:

Municipal Code-Enforcement Litigation: Plaintiffs must now marshal detailed comparator evidence at summary-judgment stage. A mere assertion that “we were treated differently than the prior owner” is insufficient.
Landlord-Tenant/Property Disputes: Where public-safety code violations are present, temporary vacate orders will likely survive Fourth-Amendment scrutiny if paired with rational safety objectives and limited in duration.
Strategic Use of Prior State Litigation: Litigants cannot rely on dismissals without prejudice to shield evidence under res judicata. The decision underscores the primacy of final judgments on the merits.
Burden Allocation: The ruling reminds plaintiffs that for procedural-due-process claims, identifying the deficient procedure—not merely alleging mistreatment—is indispensable.

Complex Concepts Simplified

Class-of-One Equal Protection: A claim that a single person (or entity) was purposely treated differently from all others without a rational reason. Think of it as alleging selective, unjustified discrimination by the government even when no protected class (race, gender, etc.) is involved.
Comparator: Another person or entity that is “alike in all relevant aspects.” If you complain of differential treatment, you must show the government treated someone almost identical to you more favorably.
Rational-Basis Review: The most lenient judicial standard. A government action survives if any plausible legitimate goal could have motivated it.
Res Judicata (“claim preclusion”): Once a final judgment is entered on the merits, the same parties cannot litigate the same claim again. “Without prejudice” means the case can be re-filed, so no preclusive effect exists.
Unreasonable Seizure: Government interference with property or personal liberty that lacks sufficient justification. Not every seizure is unconstitutional; only those lacking reasonable grounds violate the Fourth Amendment.

Conclusion

The Third Circuit’s decision in Jaramillo v. City of Coatesville offers a robust restatement—not a radical overhaul—of constitutional standards governing municipal code enforcement. The Court heightened attention to the comparator requirement in “class-of-one” Equal Protection cases, reinforced the latitude cities possess to act swiftly when public safety is threatened, and clarified that procedural-due-process plaintiffs shoulder the burden of pinpointing inadequate procedures. While not precedential, the opinion provides persuasive guidance for district courts and litigants confronting similar fact patterns across the Third Circuit and beyond.