Civil Procedure

Brief

Smuck v. Hobson

Procedural History:

• District court granted motions to intervene.
• Appealed.
• Affirmed but their interest only extends to hose parts of the order which can be fairly said to impose restraints upon the board of education.

Facts:

• Centered around a class action brought on behalf of Black and poor children.
• Court found that the children were being denied their unconstitutional rights to equal educational opportunities because the District of Columbia schools were being operated on a basis that was racially and economically discriminatory.
• The Board of Education chose not to appeal but Smuck and Hansen filed notices of appeal.
• Dr. Hansen and twenty parents who dissent brought motions to intervene.
• The District Court allowed those motions and that is what is currently on appeal.

Issue:

• Was the granting of intervention proper?

Holding:

• Yes to the parents in part, no in regarded to Smuck and Hansen.

Reasoning:

• Dr. Hansen was a named defendant in the original suit but since left his official position and thus had to move to intervene because he no longer had grounds to do so as an original defendant.
• Hansen thus has no interest relating to the property of transaction which is the subject of the action pursuant to Rule 24.
• Smuck has no appealable interest as a member of the Board of Education.
• In regards to the parents.
  • Parents unquestionably have a sufficient interest in the education of their children to justify the initiation of a lawsuit in appropriate circumstances.
  • Court used the ‘interest’ test.
• There are two goals to intervention: to achieve economies of scale by resolving related issues in a single lawsuit, and to prevent the single lawsuit from becoming fruitlessly complex or unending.
• Economic interest is not always necessary.
• The court did find that a party may be only allowed to intervene on issues which directly relate to that party and not to the lawsuit as a whole.
• The court found that the disposition of the action might impair the applicant’s ability to protect their interests if they were not allowed to intervene.
• The court then addressed if the applicant was already adequately represented in the lawsuit.
  • The burden is on the opposing intervention to show the adequacy of the existing representation.
• The court found that the interest of the parents does not coincide with that of the Board of Education and thus the parents are not adequately represented in the current lawsuit.