Mausolf v. Babbitt

Three snowmobile enthusiasts and the Minnesota United Snowmobilers Association (snowmobilers) (plaintiffs) sued the Secretary of the Interior and others (the government) (defendants) to enjoin them from enforcing snowmobile restrictions in Voyageurs National Park. Conservation groups, including the Voyageurs Regional Park Association (intervenors), motioned to intervene as-of-right on the government’s side under Federal Rule of Civil Procedure 24(a). The snowmobilers argued that the intervenors lacked Article III standing to intervene. The magistrate judge and the district-court judge concluded that the question of an intervenor’s standing is irrelevant to whether intervention must or may be allowed under Rule 24(a) and (b). Despite finding that the intervenors had an interest in the litigation that might be impaired or impeded if it were not allowed to intervene, the district court denied their motion to intervene after concluding that under the doctrine of parens patriae, government entities are presumed to represent the interests of all their citizens, so the intervenors did not meet all the criteria for Rule 24(a) intervention. The district court was not persuaded that the intervenors’ interests would be subordinated to more general, national interests, and it also declined to allow permissive intervention under Rule 24(b) because it feared the intervenors would delay the proceedings and ultimate resolution with additional discovery and party joinder. The intervenors appealed.