GHP Management Corporation v. City of Los Angeles, 2:21-cv-06311

During the COVID-19 pandemic, the City of Los Angeles enacted Ordinances Nos. 186585 and 186606 (the Eviction Moratorium) restricting residential evictions and allowing tenants a one-year repayment period for missed rent.
Fourteen plaintiffs (LLCs/LPs and a management company) owning or managing ~5,000 units sued the City alleging the Moratorium effects an uncompensated taking under the Fifth Amendment and California Constitution and seeking just compensation (not injunctive relief).
Three tenant-advocacy nonprofits (ACCE, SAJE, CES) moved to intervene as defendants to defend the Moratorium, arguing their low-income members would face displacement and increased COVID risks if protections were weakened or ended.
The City did not oppose intervention; two proposed intervenors previously intervened for tenants in a parallel challenge to the same Moratorium.
The court evaluated the motion under Fed. R. Civ. P. 24(a)(2) (intervention as of right) and Rule 24(b) (permissive intervention) applying Ninth Circuit precedent and granted intervention.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of motion to intervene	Motion is untimely	Motion is timely	Court treated motion as timely and considered it
Protectable interest under Rule 24(a)(2)	Intervenors lack a significant protectable property interest here	Intervenors have direct interest in continued applicability of Moratorium for members' housing stability	Court found intervenors possess a significant protectable interest
Practical impairment of interests by disposition	This suit concerns only these plaintiffs; limited practical effect on broader tenant protections	A favorable ruling for plaintiffs could encourage wider challenges, prompt early termination of emergency protections, and spur mass evictions	Court concluded disposition could practically impair intervenors’ ability to protect members
Adequacy of representation by the City	Government representation is presumptively adequate	City’s objectives diverge from intervenors; intervenors represent narrower, lower-income constituencies and sought broader protections the City refused	Court held intervenors met the minimal burden to show potential inadequate representation and granted intervention

California ex rel. Lockyer v. United States, 450 F.3d 436 (9th Cir. 2006) (sets four-part Rule 24(a)(2) test for intervention as of right)
Wilderness Soc. v. U.S. Forest Serv., 630 F.3d 1173 (9th Cir. 2011) (Rule 24 should be construed broadly in favor of intervenors)
United States v. City of Los Angeles, 288 F.3d 391 (9th Cir. 2002) (guidance on practical and equitable considerations for intervention)
Sw. Ctr. for Biological Diversity v. Berg, 268 F.3d 810 (9th Cir. 2001) (courts accept well-pleaded allegations in intervention motions as true)
Arakaki v. Cayetano, 324 F.3d 1078 (9th Cir. 2003) (discusses assumption of adequacy when government represents a constituency)
Oakland Bulk & Oversized Terminal, LLC v. City of Oakland, 960 F.3d 603 (9th Cir. 2020) (explains limits of showing inadequate representation against a government defendant)
Spangler v. Pasadena City Bd. of Ed., 552 F.2d 1326 (9th Cir. 1977) (permissive intervention principles)
Freedom from Religion Found., Inc. v. Geithner, 644 F.3d 836 (9th Cir. 2011) (permissive intervention and jurisdictional considerations)