Case Explained: JOLIET AVIONICS, INC v. CITY OF AURORA, ILLINOIS

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-07-29 The seventh-circuit affirmed the district court’s grant of summary judgment to the City of Aurora on both Joliet Avionics’ equal protection and breach of contract claims. Regarding the equal protection “class-of-one” claim, the court held that such a theory is inapplicable to government contracting disputes because they involve discretionary decision-making based on subjective, individualized assessments similar to those in public employment contexts, as established by *Engquist v. Oregon Dep’t of Agriculture*. The court reasoned that contract negotiations and enforcement decisions inherently require discretion, meaning differential treatment does not violate the Equal Protection Clause absent class-based discrimination or malicious application of law enforcement powers. On the breach of contract claim, the court rejected the argument that federal grant assurances and the City’s Minimum Standards policy were implicitly incorporated into the lease as enforceable contractual terms. The court explained that the implied incorporation doctrine applies only to existing statutes and laws, not to contractual agreements like FAA grant assurances or vague, aspirational policy language that does not impose concrete legal obligations on the City. Consequently, Joliet Avionics could not enforce its competitor’s lease terms or compel strict enforcement of airport policies against other tenants, and the judgment for the City stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.