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16-605 CHESTER, NY V. LAROE ESTATES, INC. DECISION BELOW: 828 F.3d 60 CERT. GRANTED 1/13/2017 QUESTION PRESENTED: Whether intervenors participating in a lawsuit as of right under Federal Rule of Civil Procedure 24(a) must have Article III standing (as three circuits have held), or whether Article III is satisfied so long as there is a valid case or controversy between the named parties (as seven circuits have held). LOWER COURT CASE NUMBER: 15-1086-cv
The Town of Chester v. Laroe Estates case in 2016 revolved around a dispute over land use and development rights. Steven Sherman, the original plaintiff, sued the town for blocking his residential development project which he claimed violated federal law. Laroe Estates Inc., who had an interest in the property as they were owed money by Sherman, sought to intervene in this lawsuit under Rule 24(a)(2) of Federal Rules of Civil Procedure (FRCP). The Supreme Court was asked to decide whether or not an intervenor must meet Article III standing requirements even if another party with constitutional standing is already present on that side of litigation. In a unanimous decision, it ruled that an intervenor seeking relief different from what is requested by a plaintiff must demonstrate Article III standing regardless if there's already another party with such standing.
In the case of Town of Chester v. Laroe Estates, there was no dissenting opinion recorded as the decision was unanimous. The Supreme Court ruled that a litigant seeking to intervene in a lawsuit as of right under Federal Rule of Civil Procedure 24(a)(2) must meet Article III's standing requirements only if they wish to pursue relief not requested by the original plaintiff. This means an intervenor needs to demonstrate their own injury-in-fact, traceability and redressability - key components for establishing legal standing - only when they seek additional or different relief from what is sought by the plaintiff. If they are merely joining in to support the same claims made by existing parties, then no separate standing is required.