## Facts

- Voyageurs National Park in northern Minnesota contains extensive lakes and islands and is used for winter recreation and wildlife viewing.
- Snowmobiling is generally prohibited in national parks, but Voyageurs’ enabling legislation allows the Secretary of the Interior to permit it subject to regulation.
- Federal agencies adopted restrictions on snowmobiling in the park, citing resource protection concerns, including effects on the gray wolf under the Endangered Species Act.
- Snowmobilers and related organizations sued federal officials to enjoin enforcement of the restrictions.
- Several environmental and conservation organizations moved to intervene on the government’s side under Federal Rule of Civil Procedure 24(a) (intervention of right) and alternatively Rule 24(b) (permissive intervention), asserting interests in wildlife protection and strict enforcement.
- The district court denied intervention of right, concluding the government adequately represented the organizations’ interests, and denied permissive intervention based on anticipated delay and complication.
- While the intervention appeal was pending, the district court granted summary judgment to the snowmobilers and enjoined enforcement of the restrictions pending further agency explanation.
- The environmental organizations appealed the denial of intervention.

## Issues

1. Whether a proposed intervenor must independently satisfy Article III standing requirements.
2. Whether the environmental organizations met the requirements for intervention of right under Rule 24(a)(2), including inadequate representation by existing parties.
3. Whether a presumption that the government adequately represents citizens’ interests can, by itself, defeat intervention of right by private organizations.
4. Whether denial of permissive intervention based on anticipated delay was proper.

## Decision

- The Eighth Circuit held that a party seeking to intervene must demonstrate Article III standing.
- The court found the environmental organizations had standing based on members’ use and enjoyment of the park and alleged harm to aesthetic and recreational interests from weakened protection.
- The court reversed the denial of intervention of right and remanded, holding the organizations satisfied Rule 24(a)(2).
- The court rejected treating government representation as conclusively adequate merely because the government and proposed intervenors generally supported enforcement of the restrictions.
- Because intervention of right was required, the court did not rely on permissive intervention.

## Legal Principles

- Article III’s case-or-controversy requirement applies at all stages of federal litigation, including motions to intervene; intervenors must show injury in fact, causation, and redressability.
- Intervention of right under Rule 24(a)(2) requires a timely motion, a cognizable interest related to the action, practical impairment of that interest from the litigation’s disposition, and inadequate representation by existing parties.
- Environmental standing may be shown when members use the affected area and allege that their aesthetic or recreational interests will be diminished by the challenged action.
- Any presumption that a governmental party adequately represents a proposed intervenor’s interests is rebuttable; the government’s obligation to represent the public interest may diverge from an organization’s more specific objectives, including litigation strategy and settlement positions.
- Practical impairment under Rule 24(a)(2) includes the risk that an adverse judgment may constrain later efforts through preclusion doctrines or precedential effects.

## Conclusion

The Eighth Circuit required intervenors to establish Article III standing and held that environmental organizations seeking to defend park-use restrictions were entitled to intervene as of right because they showed concrete environmental interests at stake and that the government’s representation of the broader public interest might not protect the organizations’ more specific enforcement objectives.


Mausolf v. Babbitt, 85 F.3d 1295 (8th Cir. 1996)