Chiles v. Thornburgh
865 F.2d 1197 (11th Cir. 1989)
Facts: In the 1980’s, federal officials utilized Krome, a correction facility in Florida, to house illegal aliens who were waiting on determinations on their status (i.e. deportation, asylum, etc.). Officials from the Bureau of Prisons and Department of Justice, including the attorney general, were called to testify before congress about the nature of the facility and the time in which inmates were housed at the facility. Senator Lawton Chiles questioned the officials during the hearings as to what the nature of the facility was. The officials assured Senator Chiles at the time that Krome remained a temporary detention center and that a permanent, longer-term facility would be ready by 1985.
Despite their assurances to the committee, Krome was used as a long-term detention facility where aliens - including convicted felons - were held indefinitely. In fall 1985, several felons rioted and broke out of the prison, causing an uproar in the community.
In the aftermath, Senator Chiles filed a complaint. Alleging the aforementioned facts, Chiles sought several forms of relief:
- a declaratory judment that the government’s affirmative misrepresentation estopped the government from operating Krome as other than a minimum security, short-term facility with a cap of 525 presons, none of whom were felons.
- declaratory and injunctive relief relating to the responsibilities of duties of the DOJ, BOP and INS with respect to Krome
- a writ of mandamus ordering the government to
- remove all alien felons from Krome and transfer them to medium security and maximum security facilities
- obey the cap on the number of aliens which can be detained at Krome
- limit detention of aliens at Krome to short-term minimum security processing stays.
After Chiles brought his claim, Dade County and Florida Governor Martinez sought to intervene. Their complains alleged the same facts and sought similar relief as Chiles, though they did not assert any different estoppel claims. The district permitted their intervention under Rule 24(b). After this intervention, detainees from Krome attempted to intervene along with a homeowners association from the area and two individual homeowners. They, too, sought the same forms of relief.
The case was dismissed. Senator Chiles and Dade County were found to not have any standing in the case. The judge also denied the proposed interventions from the prisoners on the grounds that they could file a habeas corpus petition to seek relief and the homeowners and homeowners association failed to allege an injury from the operation of Krome. In addition, the judge held that the case was centered around a nonjusticiable political question.
1) Whether Chiles or any other subsequent intervenors had standing.
2) Whether the intervenors had grounds for intervention under Rule 24.
Holding: The court upheld in part and reversed in part.
The court found that Chiles did not have standing to bring his original claim as he was not directly affected by the situation. The court did find, however, that the county had the ability to intervene and had standing.
The court then turned its attention to whether the other intervenors could move forward with their claims.
They found that the inmates who had attempted to intervene had grounds to do so as of right because they had an undoubtable interest with the outcome of the case and because their interests would most certainly be affected by the outcome of the case. The court said that the county could very well be advocating on the behalf of the residents who lived outside of the prison’s walls, and not necessarily on their behalf. The inmates were found to be analogous to prisoners who have standing to sue over the conditions of the institutions where they are being housed. Moreover, if they were not allowed to intervene, the ability of the inmates to litigate the government’s operation of Krome in a separate lawsuit might be an exercise in futility if the instant lawsuit was decided in favor of the government. Because of this, the inmates were allowed to move forward with their case and were ordered to be treated by the lower court as an original and equal party.
The homeowners and homeowners association were found to not have sufficient grounds to intervene under 24(a) or 24(b) because their interests were very much in concert with the county, thus their interests would most probably be represented in the litigation moving forward.