Chiles v. Thornburgh

Brief Fact Summary.

Plaintiff brought suit against Defendant to compel the government to operate the detention facility properly. Dade County and the Governor of Florida were allowed to intervene, but the court did not allow two Krome detainees, two homeowners, and a homeowners’ association to intervene. Thereafter, the court dismissed the action.  Plaintiff and the individuals who tried to intervene appealed.

Synopsis of Rule of Law.

. If a party seeks to intervene in federal court, the party does not required to have general standing to sue as long as the party meets the intervention requirements under FRCP 24.

Facts.

Krome Detention Center, Krome, was a minimum-security detention facility managed by the Bureau of Prisons in Dade County, Florida. Defendants, Department of Justice officials, appeared before Congress and stated that Krome used to detain individuals for a short period of time. Nonetheless, Krome was used to detain aliens and felon aliens for a long time.  After a riot, Plaintiff, United States Senator Lawton Chiles, brought suit against Defendants to obtain a declaratory, injunctive relief, and a writ of mandamus to compel the government to properly operate Krome. The court allowed Dade County and the Governor of Florida to intervene. Two Krome detainees, two homeowners, and a homeowners’ association tried to intervene. The court dismissed the action on the grounds that Plaintiff, Dade County, and the governor lacked standing to bring suit, the detainees that sought to intervene could seek habeas review, and the homeowners did not allege an injury. Plaintiffs and the individuals seeking to intervene appealed.

Issue.

Whether a party that seeks to intervene in federal court is required to have general standing to sue.

Held.

No, a party seeks to intervene in federal court, the party does not required to have general standing to sue as long as the party meets the intervention requirements under FRCP 24.

Discussion.

If a party seeks to intervene in federal court, the party does not required to have general standing to sue as long as the party meets the intervention requirements under FRCP 24.

Nevertheless, federal courts have the power to hear causes of actions and controversies, but a controversy is not present if the plaintiff does not have standing. To have standing, one must have “a personal stake in the outcome of the controversy,” and the plaintiff is required to introduce evidence that indicates actual injury was caused by the defendant’s illegal conduct that could be remedied with a favorable ruling. Also, prudential standing compels the plaintiff to be declaring his own right, so long as it is “within the zone of interest protected by” the law, not a generalized complaint. However, a party seeking to intervene under FRCP 24(a)(2)  does not require the party to have standing, solely a “significantly protectable interest.” Thus, if the original parties have standing, there is standing for the district court to hear the case. Further, to establish an intervention of right, a party must timely apply, have an interest in the cause of action, be unable to guard that interest without intervention, and existing parties do not adequately guard that interest. FRCP 24(a)(2). On the other hand, a permissive intervention requires a party to timely apply and assert a claim that shares a common legal or factual issue in the cause of action. FRCP 24(b)(2). Nonetheless, the court has discretion to grant or deny the permissive intervention. In this case, Dade County had standing to sue. Nevertheless, Chiles and the governor do not. After, the detainees motioned to intervene. Further, this court noted that their application was timely, and neither party would be prejudiced from their intervention. Also, the detainees’ claims are related to the operation of Krome, the subject matter of the cause of action. Thus, the detainees have an interest, and litigation on the matters without allow the detainees to be present may damage their ability to protect that interest in the future. Thus, the detainees should have been granted the right to intervene, pursuant to FRCP 24(a)(2). But, the homeowners and homeowners’ association interest are identical to the interest of Dade County. Consequently, the homeowners and the homeowners’ association cannot intervene as a matter of right. Overall, the district court did not abuse its discretion in denying permissive intervention to the homeowners, Chiles, and the governor, but the ruling for Dade County is reversed.