Supreme Court of the United States
Town of Chester, New York, Petitioner v. Laroe Estates, Inc.
June 5, 2017581 U.S. 433
Summary
The Supreme Court held that an intervenor of right under Federal Rule of Civil Procedure 24(a)(2) must satisfy Article III's standing requirements whenever it seeks relief different from or in addition to the relief requested by a party with standing, because for every form of relief sought some litigant—whether plaintiff, coplaintiff, or intervenor—must have standing. Because the record left ambiguous whether Laroe Estates seeks its own money judgment against the Town or only the same takings damages sought by the Sherman estate, and the Second Circuit never resolved that threshold question, the Court vacated the judgment below and remanded for that determination. The Court expressed no view on whether an intervenor pursuing only the plaintiff's identical relief needs standing, and assumed only for the sake of argument that Laroe lacks standing.
Holding
- Whether an intervenor of right must possess Article III standing to pursue relief not requested by a plaintiff.. Yes. An intervenor of right must have Article III standing in order to pursue relief that is different from that which is sought by a party with standing; for all relief sought, there must be a litigant with standing, whether that litigant joins the lawsuit as a plaintiff, a coplaintiff, or an intervenor of right. This includes cases in which the plaintiff and the intervenor seek separate money judgments in their own names.
- How that standing rule applies where the record leaves ambiguous whether the intervenor seeks the plaintiff's relief or separate relief of its own.. Because the record left it ambiguous whether Laroe seeks damages for itself or only the same damages sought by Sherman, and the Court of Appeals did not resolve that threshold question, the Court declined to answer it in the first instance and vacated the judgment below so the Court of Appeals can determine whether Laroe seeks different relief—and therefore must establish its own Article III standing—to intervene.
Docket 16–605.
Cited authorities
- Fed. R. Civ. P. 24(a)(2)
- Fed. R. Civ. P. 24(a)(2)
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