Lighthiser v. Trump

CourtDistrict Court, D. Montana
DecidedAugust 13, 2025
Docket2:25-cv-00054
StatusUnknown

This text of Lighthiser v. Trump (Lighthiser v. Trump) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lighthiser v. Trump, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BUTTE DIVISION

EVA LIGHTHISER; et al., CV 25–54–BU–DLC

Plaintiffs,

v. ORDER

DONALD J. TRUMP, in his official capacity as President of the United States; et al.,

Defendants,

STATE OF MONTANA; et al.,

Defendant-Intervenors.

Before the Court is a Motion to Intervene filed by the States of Montana, Alaska, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Louisiana, Missouri, Nebraska, North Dakota, Oklahoma, South Dakota, Texas, Utah, West Virginia, and Wyoming, as well as the U.S. Territory of Guam (collectively “Proposed State Intervenors”). (Doc. 32.) The Proposed State Intervenors seek to intervene as of right or, in the alternative, permissively. (Id. at 2.) Plaintiffs object to the intervention and Federal Defendants take no position. (Doc. 33 at 8.) For the reasons herein, the Motion will be granted. BACKGROUND On May 29, 2025, Plaintiffs— 22 youth and children from across the United

States—filed this action for declaratory and injunctive relief against three executive orders enacted by President Donald J. Trump during his first months in office. (Doc. 1.) Plaintiffs challenge (1) Executive Order 14154 §§ 1–3, 5, 7, titled

“Unleashing American Energy”; (2) Executive Order 14156, titled “Declaring a National Energy Emergency”; and (c) Executive Order 14261 §§ 2–3, 5–7, titled “Reinvigorating America’s Beautiful Clean Coal Industry and Amending Executive Order 14241” (collectively the “Challenged Executive Orders”). (Id. ¶

1.) “Implementation of the unlawful [Executive Orders],” Plaintiffs argue, “will increase fossil fuel pollution, threatening Plaintiffs’ lives, health, and safety.” (Id. ¶ 90.) Plaintiffs allege six claims for relief: (1) substantive due process violation of

the right to life; (2) substantive due process violation of the right to liberty; (3) ultra vires Presidential action to “unleash” fossil fuel pollution and debilitate the Environmental Protection Agency; (4) ultra vires Presidential action to “unleash” fossil fuels by terminating the National Climate Assessment; (5) ultra vires

Presidential action to “unleash” fossil fuels by dismantling, suppressing, and scrubbing science; and (6) substantive due process state-created danger. (Id. ¶¶ 251– 329.)

On June 13, 2025, Plaintiffs filed a Motion for Preliminary Injunction seeking to enjoin implementation of the Challenged Executive Orders. (Doc. 24.) Proposed State Intervenors filed a Motion to Intervene on July 8, 2025, (Doc. 32)

and Defendants filed a Motion to Dismiss for lack of subject matter jurisdiction and failure to state a claim on August 4, 2025 (Doc. 42). LEGAL STANDARD

To intervene as of right, the movant must demonstrate the following: (1) the motion to intervene is timely; (2) a “significantly protectable” interest relating to the property or transaction at issue; (3) the disposition of the action may, as a practical matter, impair or impede the movant’s ability to protect its interest; and

(4) the existing parties do not adequately represent the movant’s interest. Wilderness Soc’y v. U.S Forest Serv., 630 F.3d 1173, 1177 (9th Cir. 2011) (en banc); Fed. R. Civ. P. 24(a)(2). The burden lies with the applicant seeking to

intervene. Prete v. Bradbury, 438 F.3d 949, 954 (9th Cir. 2006). However “[w]hile an applicant seeking to intervene has the burden to show that these four elements are met, the requirements are broadly interpreted in favor of intervention.” Citizens for Balanced Use v. Montana Wilderness Ass’n, 647 F.3d 893, 897 (9th Cir. 2011).

To permissively intervene, the movant must demonstrate: (1) the motion is timely; (2) the movant shares a common question of law or fact with the main action; and (3) the movant has an independent basis for jurisdiction. Donnelly v.

Glickman, 159 F.3d 405, 412 (9th Cir. 1998); Fed. R. Civ. P. 24(b). “In exercising its discretion, the court must consider whether the intervention will unduly delay or prejudice the adjudication of the original parties’ rights.” Fed. R. Civ. P. 24(b)(3).

Additionally, “judicial economy is a relevant consideration in deciding a motion for permissive intervention.” Venegas v. Skaggs, 867 F.2d 527, 531 (9th Cir. 1989). “[A] liberal policy in favor of intervention serves both efficient resolution

of issues and broadened access to the courts.” Wilderness Soc’y., 630 F.3d at 1179. DISCUSSION I. Sovereign Immunity As an initial matter, the Court must address Proposed State Intervenors’

claim that intervention does not constitute a waiver of sovereign immunity. (Doc. 33 at 8.) Plaintiffs maintain that for this Court to exercise its jurisdiction over the Proposed State Intervenors, the States must be deemed to have voluntarily waived

their sovereign immunity. (Doc. 37 at 4, 37 (citing U.S. Const. amend. XI).) The Eleventh Amendment to the U.S. Constitution generally “bar[s] [] federal jurisdiction over suits” against States. Coll. Sav. Bank v. Fla. Prepaid Postsecondary Educ. Expense Bd., 527 U.S. 666, 669 (1999). An individual may

sue a State, however, if one of two exceptions is present: (1) “where Congress has authorized such a suit in the exercise of its power to enforce the Fourteenth Amendment”; or (2) “where a State has waived its sovereign immunity by

consenting to suit.” Id. at 670 (internal citation omitted). In the case of the second exception, the United States Supreme Court “has long recognized that a State’s sovereign immunity is a personal privilege which it may waive at its pleasure.” Id.

at 675 (internal quotation and citation omitted). The “test for determining whether a state has waived its immunity from federal-court jurisdiction is a stringent one.” Id. In general, a federal court “will find a waiver either if the State voluntarily

invokes [its] jurisdiction [] or else if the State makes a ‘clear declaration’ that it intends to submit itself to [the federal court’s] jurisdiction.” Id. at 676 (internal citation omitted). Relevant here, waiver of sovereign immunity may occur where a State

voluntary enters a suit in federal court. Regents of the Univ. of N.M. v. Knight, 421 F.3d 111, 1124 (Fed. Cir. 2003) (“[I]t has long been established that a state waives its Eleventh Amendment immunity when it consents to federal court jurisdiction by

voluntarily appearing in federal court.”) (citing Clark v. Barnard, 108 U.S. 436, 447 (1883) (State’s “voluntary appearance” in federal court as an intervenor avoids Eleventh Amendment inquiry); see also Gunter v. Atl. Coast Line R.R., 200 U.S. 273, 284 (1906) (“[W]here a State voluntarily becomes a party to a cause and

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