Town of Chester, New York, Petitioner v. Laroe Estates, Inc.

Intervenors must have Article III standing to pursue relief under Federal Rules of Civil Procedure 24(a)(2).

Petitioner removed the original case to Federal District Court after a land developer brought Fifth and Fourteen Amendment regulatory takings claims against Petitioner. The Federal District Court dismissed the case for ripeness, and the Court of Appeals for the Second Circuit reversed and remanded the case. On remand, Respondent filed a motion to intervene pursuant to Federal Rules of Civil Procedure 24(a)(2). The District Court denied the motion, and the Second Circuit reversed, holding that the intervenor did not need Article III standing. On review by the U.S. Supreme Court, it noted that standing principles apply to any litigant seeking relief and an intervenor of right must request different relief than that sought by another party with standing. The Court found that it was unclear from record if Respondent was seeking the same or different damages as the land developer, and the Court of Appeals failed to resolve the ambiguity. VACATED and REMANDED.