Target Logistics Management, LLC v. Williston, City of
1:16-cv-00076
D.N.D.Dec 18, 2017Background
- Plaintiffs Target Logistics Management, LLC and Lodging Solutions - Williston, LLC filed a declaratory judgment challenge (April 2016) to Williston Ordinances 1026 and 1050, which repeal special permitted use for "man camps"/"crew camps."
- Court issued a preliminary injunction against Ordinance 1026 in June 2016; Halliburton intervened the same month; the injunction was later vacated after ordinance 1050 and amendment (March 2017).
- The case was stayed by stipulation for six months in May 2017; no completed discovery or dispositive motions at time of Weatherford’s motion.
- Weatherford U.S., L.P. moved to intervene (July 31, 2017), asserting interests substantially identical to existing plaintiffs and potential impairment if excluded.
- The City of Williston opposed on timeliness and prejudice grounds; other plaintiffs and Halliburton did not oppose Weatherford’s motion.
- The court granted Weatherford intervention as of right under Federal Rule of Civil Procedure 24(a)(2) and allowed filing of a complaint in intervention.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of intervention | Weatherford: motion filed promptly given stay; case not progressed; no prejudice | City: Weatherford delayed, will prejudice ongoing settlement and parties | Timely — delay minimal, case inactive, no prejudice shown |
| Whether Weatherford has a protectable interest | Weatherford: subject to ordinances; interest aligns with plaintiffs | City: relied on untimeliness/prejudice; did not contest interest | Has a sufficient interest in the subject matter |
| Whether disposition may impair Weatherford's interests | Weatherford: a ruling upholding ordinances would force compliance / impair rights | City: did not rebut impairment argument | Court: disposition could impair Weatherford’s interests |
| Adequacy of existing representation | Weatherford: existing parties may not protect its specific interests; might not be covered by settlements | City: did not meaningfully argue adequacy | Representation inadequate (minimal showing met); intervention of right granted |
Key Cases Cited
- In re Wholesale Grocery Prod. Antitrust Litig., 849 F.3d 761 (8th Cir. 2017) (factors to assess timeliness of motion to intervene)
- Mille Lacs Band of Chippewa Indians v. State of Minn., 989 F.2d 994 (8th Cir. 1993) (ongoing settlement negotiations do not automatically establish prejudice; minimal burden for inadequate representation)
- Nat’l Parks Conservation Ass’n v. United States Envtl. Prot. Ass’n, 759 F.3d 969 (8th Cir. 2014) (motions to intervene construed liberally; allegations taken as true)
- South Dakota ex rel. Barnett v. United States Dept. of Interior, 317 F.3d 783 (8th Cir. 2003) (elements required for intervention as of right under Rule 24(a)(2))
- Sierra Club v. Robertson, 960 F.2d 83 (8th Cir. 1992) (doubts about intervention resolved in favor of allowing it)