The Episcopal Church in the Diocese of Connecticut v. Ronald S. Gauss

Summary

The court affirmed the denial of an association's motion to intervene as of right in a church-property dispute. It held that the association's interests were adequately represented by the existing defendants because the association and defendants shared overlapping identities and the same ultimate objective of retaining possession and control of the property. The court also held that no evidentiary hearing was required because intervention was evaluated from the pleadings, whose allegations were accepted as true, and the pleadings established adequate representation.