Mausolf v. Babbitt

85 F.3d 1295 (8th Cir. 1996)



The irreducible constitutional minimum of standing required by Article III has three elements: First, the would-be litigant must have suffered an "injury in fact;" that is, an invasion of a legally protected interest which is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical. Second, the would-be litigant must establish a causal connection between the alleged injury and the conduct being challenged. Third, he must show that the injury is likely to be redressed by a favorable decision.


The plaintiffs, three snowmobile enthusiasts and the Minnesota United Snowmobilers Association (collectively, "the Snowmobilers"), sued the Secretary of the Interior and other defendants ("the Government"), seeking to enjoin the enforcement of restrictions on snowmobiling in Voyageurs National Park. The Voyageurs Region National Park Association and other conservation groups (collectively, "the Association") moved to intervene so it could vindicate its interest in restricting snowmobiling in the Park and in making sure the new regulations were strictly enforced. The Association contended that for years the Government illegally, and over the Association's objections, permitted unrestricted snowmobiling in the Park and refused to implement proper wilderness-protection measures. The Association asserts that the Government cannot be trusted to protect the Association's interests because of its alleged history of siding with the Snowmobilers. The District Court conceded that the Association had a recognized interest which might be impaired by the disposition of the case, however, the Court noted that under the parens patriae doctrine, government entities are presumed to represent the interests of all their citizens. Therefore, the District Court was not persuaded that the Government would unduly subordinate the Association's interests to more general, national interests, and, therefore, denied the Association’s petition to intervene.


Do conservation groups have legal standing to intervene in proceedings regarding the enforcement of restrictions on snowmobiling in Voyageurs National Park?




The Court held that the conservation groups had standing because their claims that snowmobiling threatened animals in the park and detracted from the park's tranquility and beauty established concrete, imminent, and redressable injuries in fact, which were neither conjectural nor hypothetical. The Court posited that the presumption of adequate representation applied under the parens patriae doctrine, but concluded that the conservation groups had rebutted that presumption by showing that the government had failed to enforce its regulations against snowmobile use and that the government could not adequately represent the conflicting interests of recreation and conservation.

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