United States filed lawsuit on behalf of United States Department of Agriculture (USDA), seeking to enjoin dissolution of county sewer district. Group of voters, customers, ratepayers, and property owners moved to intervene. The United States District Court denied motion, and group appealed. While appeal was pending, parties sought court approval for asset purchase agreement to sell district’s assets to private entity and finally dissolve district, and group renewed its motion to intervene. The District Court denied motion, and group appealed.
The Court of Appeals held that alleged violation of group’s interest in upholding vote to dissolve county sewer district did not establish standing to intervene.
Alleged violation of interest of group of voters, customers, ratepayers, and property owners in upholding vote to dissolve county sewer district and immediately dissolving district did not state specific individualized injury necessary to establish standing in federal court to intervene in United States government’s action seeking to enjoin dissolution of county sewer district, since interests were shared by all voters who voted to dissolve district, and existing parties had not ignored or attempted to undermine vote in support of dissolution, and sought to effectuate district’s dissolution in accordance with Missouri law, which required “no district shall be dissolved until all of its outstanding indebtedness has been paid.”
Group of voters, customers, ratepayers, and property owners failed to show that any injury to interest in opposing repayment of revenue bond county sewer district issued to United States Department of Agriculture (USDA) was actual or imminent, and thus group did not state specific individualized injury necessary to establish standing in federal court to intervene in United States government’s action seeking to enjoin dissolution of county sewer district. Through lawsuit, parties arranged a solution for repaying USDA that would lower rates, and group’s alleged injury would arise only if sale of district’s sewer system failed to close, USDA continued to demand payment on revenue bond, and district raised rates to pay the bond obligation.
Group of voters, customers, ratepayers, and property owners failed to establish that enforcement of Missouri environmental and administrative regulations amounted to a “personal and individual” injury necessary to establish standing in federal court to intervene in United States government’s action seeking to enjoin dissolution of county sewer district, where group asserted only a generalized grievance, which was available to all members of sewer district.
Alleged violation of interest of group of voters, customers, ratepayers, and property owners in proposing on-site sewage treatment alternatives did not state specific individualized injury necessary to establish standing in federal court to intervene in United States government’s action seeking to enjoin dissolution of county sewer district, since any injury group could suffer with regard to ability to construct on-site systems was not “personal and individual” to group, and it was not caused by dissolution of district.