What did the Supreme Court Decide in Town of Chester v. Laroe Estates?
In Town of Chester v. Laroe Estates, the Supreme Court of the United States held that an intervenor as of right – – meaning a party asserting the right to intervention under F.R. Civ. P 24 – – must also demonstrate that it has Article III standing if it seeks relief different from what the original plaintiff is seeking.
Rule 24 of the Federal Rules of Civil Procedure allows a non-party to intervene in a litigation. Intervention is where a non-party moves to join the litigation as either a plaintiff or defendant. A party may seek to intervene as a matter of right if it has has an interest in something that is the subject of the litigation and its interests are not being protected by the parties in the litigation.
Article III Standing
Article III of the United States Constitution empowers the judicial branch of the federal government – – US federal courts – – to hear cases that involve an actual case or controversy. An actual case or controversy requires that the plaintiff in the litigation have standing. A plaintiff has standing if (i) plaintiff suffered an injury; (ii) plaintiff’s injury was allegedly caused by defendant; and (iii) the court can provide relief.
Standing is important because it is connected to the principle of separation of powers. The Constitution assigns powers to each branch of government and no branch of the federal government may exceed the powers assigned to it by the Constitution. The judicial branch cannot rule on cases where the plaintiff does not have standing because that would exceed the powers granted to the federal courts by the Constitution.
In a litigation where there is more than one plaintiff, at least one plaintiff must have standing to seek each form of relief being requested in the litigation. For example, if two plaintiffs sue a defendant and the Complaint seeks both money damages and injunctive relief, at least one plaintiff must have standing to seek monetary damages and at least one plaintiff must have standing to seek injunctive relief.
In Town of Chester, the original plaintiff, a developer named Mr. Sherman, wanted to build on land in a town in New York. Mr. Sherman claimed he was unable to build because the state imposed unfair and difficult rules.
Another real estate developer, Laroe Estates, claimed to have an interest in the outcome of the litigation because of its dealings with Mr. Sherman regarding the same property. Laroe Estates moved to intervene as of right because Mr. Sherman would not adequately represent its interests.
Supreme Court Decision
The issue for the Supreme Court was whether Laroe Estates, as an intervenor, needed Article III standing.
The Supreme Court held that if Laroe Estates wanted relief different from Mr. Sherman, it would need Article III standing. For example, if Laroe Estates wanted a money judgment in its own name, Laroe Estates would need Article III standing to intervene.
The Court explained that where there is more than one form of relief being sought in the Complaint, at least one plaintiff must have standing to seek each form of relief. For this reason, Laroe Estates as an intervenor would need Article III standing if it wanted a form of relief different from the original plaintiff.