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Association of Connecticut Lobbyists LLC v. Garfield

Citations: 241 F.R.D. 100; 2007 U.S. Dist. LEXIS 13644; 2007 WL 613856Docket: Civil Action No. 3:06cv1030 (SRU)

Court: District Court, D. Connecticut; February 26, 2007; Federal District Court

Narrative Opinion Summary

This case involves consolidated lawsuits challenging the constitutionality of Connecticut's campaign finance reform law, which restricts lobbyist contributions and establishes a public election funding system. The plaintiffs seek declaratory and injunctive relief, alleging violations of the First and Fourteenth Amendments of the U.S. Constitution and Connecticut constitutional provisions. Proposed intervenors, including former candidates and non-profit lobbying organizations, have moved to intervene, supporting the law as a measure to level the electoral playing field. The court grants permissive intervention under Rule 24(b) of the Federal Rules of Civil Procedure, recognizing the intervenors' substantial interest in the case and their potential to contribute to the legal discourse. The court emphasizes that the intervenors' claims overlap with the main action, and their participation will not delay proceedings or prejudice existing parties. While the government aims to defend the law broadly, the intervenors focus on its specific impacts on their activities. The court finds the intervention timely, enhancing the case's factual and legal examination, and notes potential inadequacies in government representation of the intervenors' distinct interests.

Legal Issues Addressed

Assessment of Permissive Intervention Factors

Application: The court considers several factors for permissive intervention, including the intervenors' interests, potential benefits from intervention, and their contribution to the factual development and resolution of legal questions.

Reasoning: Courts assess several factors for permissive intervention under Rule 24(b)(2), including: (1) the applicant's potential benefits, (2) the nature and extent of the intervenors' interests, (3) the adequacy of representation of those interests by existing parties, and (4) the intervenors' contribution to the factual development and equitable resolution of legal questions.

Permissive Intervention under Rule 24(b)

Application: The court permits intervention by proposed intervenors in a case challenging campaign finance reform laws, as their claims share common legal and factual questions with the main action, and their involvement will not unduly delay or prejudice the original parties.

Reasoning: The court determines that permissive intervention is appropriate, as their claims share common legal and factual questions with the main action, and intervention will not unduly delay or prejudice the original parties.

Potential Inadequacy of Government Representation

Application: The court acknowledges concerns that the government may not adequately represent the intervenors' interests, which justifies their participation in the case.

Reasoning: Although the government shares a similar objective in defending the law's constitutionality, there are concerns that the intervenors' interests may not be fully represented by the government.

Timeliness of Intervention

Application: The court finds the intervenors' motion to intervene timely, as it was filed shortly after the original defendants' answer and during the early stages of litigation.

Reasoning: In this case, the movants' petition to intervene is timely, filed shortly after the original defendants' answer and during the early stages of litigation.