Limitation on Public Officials' Right to Intervene in Prison Conditions Litigation: In Martin Harris et al. v. Pernsley

Limitation on Public Officials' Right to Intervene in Prison Conditions Litigation: In Martin Harris et al. v. Pernsley

Introduction

The case of Martin Harris, Albert Anthony, Orlando X. McCrea, Tyronne Glenn, Carlos Royster, Amin Abdullah, Khalid Allah Muhammad, and Arnold Rutick, Charles Oakes, Emanuel Gardner v. Irene Pernsley et al., decided by the United States Court of Appeals for the Third Circuit in 1987, addresses significant issues regarding the rights of public officials to intervene in federal litigation. Specifically, it examines whether the District Attorney (DA) of Philadelphia has the right to intervene as a defendant in a lawsuit challenging prison conditions under Rule 42 U.S.C. § 1983.

Summary of the Judgment

The DA of Philadelphia sought to intervene in a federal lawsuit filed by inmates against various city officials, alleging that prison conditions violated the Eighth and Fourteenth Amendments. The district court denied the DA's motion to intervene, leading to an appeal. The Third Circuit affirmed the district court's decision, holding that the DA did not possess a sufficient interest under Federal Rule of Civil Procedure 24(a)(2) to warrant intervention as of right. The majority opinion emphasized the lack of a direct and substantial legal interest, while dissenting judges argued that the DA's prosecutorial duties were significantly impacted by the settlement, thus justifying intervention.

Analysis

Precedents Cited

The court referenced several key precedents in evaluating the DA's motion to intervene:

  • Commonwealth of Pennsylvania v. Rizzo: Established the criteria under Rule 24(a)(2) for intervention of right, emphasizing the necessity of a direct and substantial interest.
  • Restor-A-Dent Dental Laboratories, Inc. v. Certified Alloy Products, Inc.: Highlighted the complexity in defining what constitutes a "significantly protectable" interest.
  • JACKSON v. HENDRICK: A state court case challenging the constitutionality of prison conditions, which was central to the district court's original abstention ruling.
  • HINES v. D'ARTOIS and Neusse v. Camp: Provided interpretations of what constitutes a legally protectable and direct interest for intervention.

These cases collectively informed the court's assessment of the DA's eligibility to intervene, focusing on the nature and extent of his interests in the litigation.

Impact

This judgment has profound implications for public officials seeking to intervene in federal litigation. It clarifies the stringent requirements for intervention of right, particularly emphasizing the necessity for a direct and substantial legal interest. Public officials must demonstrate that their official duties are directly and significantly impacted by the litigation's outcome to qualify for intervention.

Furthermore, the case underscores the court's discretion in balancing the necessity for efficient litigation against the rights of intervenors. It sets a precedent that general interests or indirect impacts on official duties may not suffice for intervention, potentially limiting the avenues for public officials to participate in certain types of litigation.

Complex Concepts Simplified

Federal Rule of Civil Procedure 24(a)(2)

Rule 24(a)(2) allows individuals or entities to intervene in a lawsuit if they claim an interest relating to the subject matter of the action and if that interest may be impaired by the court's decision. This rule ensures that all parties with a significant stake in the litigation can present their views.

Consent Decree

A consent decree is a legal agreement entered into by the parties in a lawsuit under the supervision of a judge. It resolves the dispute without admission of guilt or liability, often outlining specific actions the defendant must take.

Intervention of Right vs. Permissive Intervention

Intervention of right is a mandatory process where a court must allow intervention if specific criteria are met. Permissive intervention, on the other hand, is discretionary and may be granted based on the court's assessment of the circumstances.

Conclusion

The Third Circuit's decision in Martin Harris et al. v. Pernsley underscores the high threshold public officials must meet to intervene in federal litigation. By affirming the district court's denial of the DA's motion to intervene, the court emphasized the need for a direct and substantial legal interest, rather than a general or indirect one. This ruling serves as a critical reference point for future cases involving the intervention rights of public officials, ensuring that only those with clear and significant stakes in the litigation's outcome are permitted to partake.

Case Details

MARTIN HARRIS, ALBERT ANTHONY, ORLANDO X. McCREA, TYRONE GLENN, CARLOS ROYSTER, AMIN ABDULLAH, KHALID ALLAH MUHAMMAD, AND ARNOLD RUTICK, CHARLES OAKES, EMANUEL GARDNER v. IRENE PERNSLEY, INDIVIDUALLY AND IN HER OFFICIAL CAPACITY AS COMMISSIONER OF THE DEPARTMENT OF HUMAN SERVICES OF THE CITY OF PHILADELPHIA, ROYAL L. SIMS, REV. ALBERT CAMPBELL, LABORA BENNETT, JAMES BARBER, MARK MENDEL, DONALD PADOVA, EACH INDIVIDUALLY AND IN HIS OR HER OFFICIAL CAPACITY AS A MEMBER OF THE BOARD OF TRUSTEES OF THE PHILADELPHIA PRISON SYSTEM, DAVID S. OWENS, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS SUPERINTENDENT OF THE PHILADELPHIA PRISON SYSTEM, GUETON CURIONE, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS WARDEN OF HOLMESBURG PRISON, PHILLIP DUKES INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS WARDEN OF THE DETENTION CENTER, JOHN DAUGHEN, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS WARDEN OF THE HOUSE OF CORRECTIONS, RODNEY D. JOHNSON, INDIVIDUALLY, LEO C. BROOKS, INDIVIDUALLY, JAMES S. WHITE, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS MANAGING DIRECTOR OF THE CITY OF PHILADELPHIA, WILLIAM J. GREEN, INDIVIDUALLY, HON. WILSON GOODE, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS MAYOR OF PHILADELPHIA, CITY OF PHILADELPHIA, JAY C. WALDMAN, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS GENERAL COUNSEL FOR THE COMMONWEALTH OF PENNSYLVANIA, RONALD J. MARKS, INDIVIDUALLY, GLEN JEFFES, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF THE PENNSYLVANIA DEPARTMENT OF CORRECTIONS. APPEAL OF RONALD D. CASTILLE, DISTRICT ATTORNEY OF PHILADELPHIA COUNTY, PROPOSED INTERVENOR.
Year: 1987
Court: United States Court of Appeals, Third Circuit.

Judge(s)

Collins Jacques SeitzLeonard I. Garth

Attorney(S)

Sarah B. Vanderbraak (argued), Chief, Civil and Exceptional Litigation, Harriet R. Brumberg, Asst. Dist. Atty., Ronald Eisenberg, Chief, Appeals Unit, Gaele McLaughlin Barthold, Deputy Dist. Atty., Office of the Dist. Atty., Philadelphia, Pa., for appellant. David Richman (argued), Philip H. Lebowitz, Thomas J. Wamser, Mary P. Hughues, Pepper, Hamilton Sheetz, Philadelphia, Pa., for appellees Martin Harris, Albert Anthony, Orlando X. McCrea, Tyronne Glenn, Carlos Royster, Amin Abdullah, Khalid A. Muhammad, Arnold Furtick, Charles Oakes and Emanuel Gardner. Handsel B. Minyard, City Sol., Richard J. Gold, Chief Deputy City Sol. (argued), Guy P. Vilim, Chief Asst. City Sol., Doris M. Leisch, Asst. City Sol., Office of the City Sol., Philadelphia, Pa., for all City of Philadelphia appellees.

Comments