## Facts

- Simpson Redwood Company filed an action to quiet title and for declaratory relief against the State of California concerning parcels in Humboldt County within Township 12 North, Range 1 East, Humboldt Meridian, near or within Prairie Creek Redwoods State Park.
- The dispute arose from conflicting boundary and title theories linked to an early government survey later discredited for irregularities and fraud, followed by a corrective resurvey that altered township and section lines.
- The Save-the-Redwoods League had acquired redwood lands and conveyed substantial portions to the State by grant deeds containing conditions requiring state-park use and conservation purposes.
- The League had also arranged for donor memorial redwood groves to be formally designated by the State; multiple designated groves were located on land Simpson claimed.
- The League moved to intervene under California Code of Civil Procedure § 387(a) while the State and Simpson pursued summary judgment; the trial court denied intervention (and also denied summary judgment).
- The League appealed only the denial of intervention; appellate proceedings stayed the trial court case.

## Issues

1. Whether the League had a sufficiently direct and immediate interest in the subject property to support permissive intervention under California Code of Civil Procedure § 387(a).
2. Whether allowing the League to intervene would unduly delay, complicate, or prejudice the quiet title action.
3. Whether the trial court abused its discretion by denying permissive intervention given the League’s deed-condition and memorial-grove related interests.

## Decision

- The Court of Appeal reversed the order denying the League’s motion to intervene.
- The court held the trial court abused its discretion in denying permissive intervention under § 387(a).
- The case was remanded for further proceedings with the League permitted to participate as an intervening party.

## Legal Principles

- Permissive intervention under California Code of Civil Procedure § 387(a) may be granted when the applicant shows a direct and immediate interest in the litigation or the property at issue and intervention will not unduly delay or prejudice existing parties.
- A qualifying interest is one such that the applicant will gain or lose by the direct legal effect of the judgment.
- A governmental party’s participation does not automatically establish adequate protection of a proposed intervener’s distinct, legally protectable interests; courts consider whether the intervener has additional, particularized interests that may be affected by the judgment.
- When intervention can help resolve related property and contractual interests in a single action and the case is at a stage where intervention will not materially disrupt proceedings, denial of intervention may constitute an abuse of discretion.

## Conclusion

The appellate court required permissive intervention because the League’s conservation deed conditions and memorial-grove commitments were concrete interests that could be impaired by a quiet title judgment, and participation would not cause undue delay or prejudice.


Simpson Redwood Co. v. State, 196 Cal. App. 3d 1192, 242 Cal. Rptr. 447 (Ct. App. 1st Dist. 1987)