## Facts

- The Krome Detention Center in Dade County, Florida, was operated by the Bureau of Prisons as a minimum-security federal detention facility for aliens.
- Federal officials represented to Congress that Krome would be used only for short-term detention and that a permanent long-term facility would be built.
- Krome was allegedly used for long-term detention, including of “felon aliens,” and conditions deteriorated, culminating in a riot.
- A United States Senator sued the Attorney General and other federal officials for declaratory and injunctive relief and mandamus, alleging unlawful operation of Krome and reliance on representations made to Congress.
- The Governor of Florida and Metropolitan Dade County intervened as plaintiffs; detainees and nearby homeowners (and an association) sought intervention.
- The district court dismissed the complaints for lack of standing and as presenting nonjusticiable political questions, and denied intervention to the detainees and homeowners.

## Issues

1. Whether the Senator, the Governor, and Dade County had Article III standing to challenge the federal operation of Krome.
2. Whether the claims were barred as nonjusticiable political questions because they implicated immigration detention and related policy choices.
3. Whether proposed intervenors under Federal Rule of Civil Procedure 24(a)(2) must demonstrate independent Article III standing.

## Decision

- The Eleventh Circuit affirmed in part, reversed in part, and remanded.
- It largely agreed that the Senator and the Governor did not establish Article III standing based on asserted institutional or generalized grievances, and it limited Dade County’s standing depending on the specific asserted injuries and claims.
- It rejected dismissal of the entire action on political question grounds, holding that specific statutory and constitutional challenges to the facility’s operation could be justiciable.
- It held that an intervenor seeking intervention as of right under Rule 24(a)(2) need not establish independent Article III standing when a valid case or controversy already exists between original parties, and it reversed the denial of intervention to the extent inconsistent with that rule.

## Legal Principles

- Article III standing requires a concrete and particularized injury fairly traceable to the defendant and likely to be redressed by judicial relief; generalized or institutional complaints about government conduct are insufficient.
- Prudential standing limits plaintiffs to asserting their own rights and generally bars generalized grievances outside the zone of interests of the invoked law.
- The political question doctrine does not bar adjudication merely because a dispute touches immigration or detention policy; courts may resolve discrete statutory and constitutional claims using judicially manageable standards.
- Rule 24(a)(2) intervention turns on a significantly protectable interest, potential impairment of that interest, and inadequate representation by existing parties.
- Rule 24(a)(2) does not require a proposed intervenor to show independent Article III standing when the underlying case already satisfies Article III.

## Conclusion

The Eleventh Circuit narrowed the plaintiffs’ standing, held that political question dismissal was overbroad because some claims were judicially resolvable, and ruled that Rule 24(a)(2) intervenors need not independently satisfy Article III standing where an existing case or controversy is already before the court.


Chiles v. Thornburgh, 865 F.2d 1197 (11th Cir. 1989)