Town of Chester v. Laroe Estates, Inc.
137 S. Ct. 1645
| SCOTUS | 2017Background
- In 2001 Steven Sherman bought ~400 acres in Chester, NY to develop the MareBrook subdivision and later sued the Town alleging regulatory obstruction and a Fifth/Fourteenth Amendment regulatory takings claim.
- Sherman’s federal takings claim was initially dismissed as unripe; the Second Circuit reversed and remanded.
- Laroe Estates, a real-estate developer that paid Sherman over $2.5 million and claimed an equitable interest in the property under New York law, moved to intervene of right under Fed. R. Civ. P. 24(a)(2).
- Laroe filed an intervenor complaint asserting a takings claim substantively identical to Sherman’s but seeking a judgment awarding damages “to Laroe.”
- The District Court denied intervention for lack of Article III standing; the Second Circuit reversed, holding intervenors of right need not meet Article III standing. The Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument (Sherman / Laroe) | Defendant's Argument (Town) | Held |
|---|---|---|---|
| Whether an intervenor of right must satisfy Article III standing to pursue relief | Laroe: if not seeking relief different from Sherman, no separate standing required | Town: intervenor must have Article III standing to pursue relief | An intervenor of right must have Article III standing when it seeks relief different from that sought by a party with standing |
| Whether Laroe sought different relief (separate money judgment to Laroe) | Laroe: argued damages overlap with Sherman and benefits flow to Sherman’s recovery (ambiguous) | Town: Laroe’s intervenor complaint sought a judgment awarding damages to Laroe (i.e., distinct relief) | Court of Appeals must determine on remand whether Laroe seeks distinct relief; if so Laroe must show standing |
| Whether at least one litigant must have standing for each form of relief | Sherman: standing for his claimed relief was litigated; Laroe: claimed equitable interest would be impaired if excluded | Town: enforcement of Article III requires standing for each form of relief | Court reiterated rule: standing must be shown for each claim and each form of relief; applies to intervenors of right seeking additional relief |
| Proper disposition of Second Circuit’s decision reversing denial of intervention | Laroe: sought intervention to protect its interest and assert identical takings claim | Town: challenged intervenor standing and the District Court’s conclusion | Supreme Court vacated the Second Circuit judgment and remanded for clarification whether Laroe seeks separate relief requiring Article III standing |
Key Cases Cited
- Davis v. Federal Election Comm’n, 554 U.S. 724 (standing must be shown for each claim and each form of relief)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (Article III limits federal judicial power)
- Simon v. Eastern Ky. Welfare Rights Organization, 426 U.S. 26 (standing requires personal stake to justify judicial relief)
- Clapper v. Amnesty Int’l USA, 568 U.S. 398 (standing rooted in separation-of-powers principles)
- Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (standing must be shown for each form of relief sought)
- City of Los Angeles v. Lyons, 461 U.S. 95 (standing distinctions between damages and injunctive relief)
- General Building Contractors Assn., Inc. v. Pennsylvania, 458 U.S. 375 (noting need to address standing when a party seeks relief different from plaintiffs)
- Cutter v. Wilkinson, 544 U.S. 709 (Court of review not of first view)
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus disclaimer on non-opinion status)