Planned Parenthood v. CCA

In 1976, after deciding to expand services to offer abortions, Planned Parenthood of Minnesota, Inc. (Planned Parenthood) (plaintiff) arranged to purchase a building in St. Paul that would accommodate all facets of its operation. Following public protests against the facility’s proposed establishment, the city council enacted an ordinance placing a six-month moratorium on construction. Planned Parenthood then brought an action against the city of St. Paul, as well as its city-council members, mayor, city attorney, city architect, and supervisor of inspectors (collectively, the city) (defendants), questioning the constitutionality of the ordinance and alleging acts of discrimination and bad faith by the city. Soon after, pursuant to Federal Rule of Civil Procedure (FRCP) 24, a neighborhood association—the Citizens for Community Action (CCA)—and two couples who owned property in the area (the owners) filed an application for intervention, seeking to join the action as defendants. CCA’s purpose for intervening was to protect property values, as well as public health, welfare, and safety. The owners also sought to intervene for the purpose of protecting their property values. The district court held that their application for intervention did not satisfy the requirements necessary to establish a right to intervene under FRCP 24(a)(2). CCA and the owners appealed.