United States v. Jankowski – Do It For The Caselaw

Holding: The Sixth Circuit affirmed the district court's denial of the motion to intervene because the motion was untimely under Federal Rule of Civil Procedure twenty-four.
Standard: Federal Rule of Civil Procedure twenty-four(a) timeliness test
Vote: Unanimous decision affirming the district court's ruling.
Practical effect: The ruling reinforces that motions to intervene must be filed promptly after a party becomes aware of their interest in a case, particularly after dispositive motions have been resolved.

The Sixth Circuit affirmed the district court's denial of a motion to intervene in a government foreclosure proceeding. The court held that the proposed intervenor's motion was untimely under Federal Rule of Civil Procedure twenty-four.

Background

Following a criminal conviction for drug trafficking and health care fraud, the government initiated foreclosure proceedings against real property owned by the defendant. The defendant’s spouse filed a notice of interested party and later a motion to intervene, claiming a vested interest in the property. The district court denied the motion, finding it untimely and an attempt to delay the proceedings.

The court’s reasoning

The court applied the five-factor test for timeliness under Federal Rule of Civil Procedure twenty-four. It found that the motion was filed over a year after the lawsuit began, after discovery had closed and summary judgment was granted. The court determined that the intervenor knew of the case from its inception and that allowing intervention at this late stage would prejudice the government by causing undue delay and requiring reconsideration of prior rulings.

We therefore conclude that the motion to intervene was untimely and that the district court did not abuse its discretion in denying the appellant’s motion.

NAACP v. New York, 413 U.S. 345, 369 (1973)

What it means going forward

The ruling reinforces that motions to intervene must be filed promptly after a party becomes aware of their interest in a case, particularly after dispositive motions have been resolved.