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Township of South Fayette v. Allegheny County Housing Authority

Citations: 183 F.R.D. 451; 1998 U.S. Dist. LEXIS 18783; 1998 WL 838904Docket: No. CIV.A. 98-1565

Court: District Court, W.D. Pennsylvania; November 16, 1998; Federal District Court

Narrative Opinion Summary

In this case, several municipalities in Allegheny County sought to intervene in a lawsuit initiated by the Township of South Fayette, which sought injunctive relief against the placement of scattered-site public housing units mandated by a Consent Decree from the Sanders case. The municipalities, including various boroughs and townships, cited concerns about improper notice and non-compliance with the decree, arguing that their interests needed separate representation to avoid overlapping litigation. The court considered the motions under Federal Rule of Civil Procedure 24, which provides for intervention as of right and permissive intervention. The court found that the movants did not demonstrate a significant, protectable interest that was not adequately represented by the existing parties, nor did they comply with procedural requirements by failing to submit necessary pleadings under Rule 24(c). Additionally, the court noted that the legal issues raised by the movants had been previously ruled upon and affirmed in related cases, rendering further intervention unnecessary. Consequently, the court denied the motions for intervention to prevent undue delay in the proceedings.

Legal Issues Addressed

Intervention as of Right under Federal Rule of Civil Procedure 24(a)

Application: The court denied intervention because the movants failed to demonstrate a significant, protectable interest that could be impaired by the action and that their interests were not adequately represented by the existing parties.

Reasoning: The movants do not claim a statutory right to intervene, nor do they possess a legally cognizable interest in the case regarding the placement of public housing units in South Fayette.

Permissive Intervention under Federal Rule of Civil Procedure 24(b)

Application: The court denied permissive intervention, exercising its discretion due to the lack of a statutory right and because allowing intervention would cause undue delay without contributing new legal arguments.

Reasoning: Furthermore, although movants seek permissive intervention under Rule 24(b) due to shared legal or factual questions with South Fayette, the court will exercise its discretion to deny this request.

Procedural Requirements for Intervention under Rule 24(c)

Application: The motions to intervene were dismissed due to non-compliance with procedural requirements, as the movants failed to provide the necessary independent pleadings detailing their specific claims or defenses.

Reasoning: Movants failed to submit the required pleading under Rule 24(c) detailing the specific claims for intervention.