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Town of Chester v. Laroe Estates, Inc.

Supreme Court of the United States · 2017 · Civil Procedure

Civil ProcedureInterventionArticle III StandingRule 24(a)(2)intervention of rightArticle IIIstandingrelief sought

Facts

Sherman sued the Town alleging that its regulatory obstruction of his development project gave rise to, among other things, a federal takings claim. Laroe later moved to intervene of right, alleging that agreements with Sherman gave it an equitable ownership interest in the property at issue. Laroe filed an intervenor's complaint asserting a takings claim substantively identical to Sherman's, but its complaint requested a judgment awarding damages to Laroe for the taking of Laroe's interest in the property. The record, however, also contained statements suggesting Laroe might be seeking only the same fund or recovery sought by Sherman.

Issue

Must a litigant have Article III standing in order to intervene of right under Rule 24(a)(2)? More specifically, must an intervenor of right establish its own standing when it seeks relief different from that requested by a plaintiff who already has standing?

Rule

For all relief sought in federal court, there must be a litigant with Article III standing. Accordingly, an intervenor of right must demonstrate Article III standing when it seeks relief different from that sought by a party with standing, including when it seeks a separate money judgment in its own name.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Elena Ruiz sued the City of Denver in federal court, alleging that a redevelopment freeze effected a taking of her warehouse parcel and seeking just compensation for her ownership interest. Summit Harbor Ventures moved to intervene of right, claiming an equitable interest in the same parcel under a private agreement with Elena, and its proposed complaint requested a damages award payable to Summit Harbor Ventures for the taking of its own interest.

Under the governing Article III rule, must the proposed intervenor establish its own standing?

Explanation. For all relief sought in federal court, there must be a litigant with Article III standing. An intervenor of right must demonstrate standing when it seeks relief different from that sought by a party with standing. A separate damages award payable to the intervenor for its own interest is different relief, even if the legal theory mirrors the plaintiff's claim.