Montana Environmental Information Center v. Montana Department of Environmental Quality

CourtDistrict Court, D. Montana
DecidedNovember 1, 2023
Docket4:23-cv-00028
StatusUnknown

This text of Montana Environmental Information Center v. Montana Department of Environmental Quality (Montana Environmental Information Center v. Montana Department of Environmental Quality) 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
Montana Environmental Information Center v. Montana Department of Environmental Quality, (D. Mont. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION

MONTANA ENVIRONMENTAL

INFORMATION CENTER, SIERRA CV-23-28-GF-BMM CLUB, WILDEARTH GUARDIANS, and

CITIZENS FOR CLEAN ENERGY,

ORDER Plaintiffs,

v.

MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY, CHRISTOPHER DORRINGTON, in his official capacity as director of Montana Department of Environmental Quality, and DAN WALSH, in his official capacity as Bureau Chief of the Mining Bureau of the Montana Department of Environmental Quality, Defendants.

INTRODUCTION The Montana Attorney General, acting on behalf of the State of Montana (“the State”), filed a motion to intervene in this action on August 3, 2023. (Doc. 12.) Montana Environmental Information Center, Sierra Club, Wildearth Guardians, and Citizens for Clean Energy (collectively “Plaintiffs”) oppose the State’s motion to intervene (Doc. 16.) Westmoreland Rosebud Mining LLC (“Westmoreland”) filed a motion to intervene on August 29, 2023. (Doc. 17.) Plaintiffs stipulated to Westmoreland’s intervention on September 13, 2023. (Doc. 22.) Plaintiffs and the

Montana Department of Environmental Quality, Christopher Dorrington, and Dan Walsh (collectively “Defendants”) filed a joint motion for a consent decree on September 22, 2023. (Doc. 24.)

The Court allowed the State and Westmoreland to submit provisional briefs concerning the joint motion for a consent decree. (Doc. 29.) The Court also allowed the existing parties to file supplemental briefs concerning the proposed consent decree. (Id.) The State filed an objection to the consent decree on October 16, 2023.

(Doc. 33.) Westmoreland filed an objection to the proposed consent decree on October 13, 2023. (Doc. 31.) Defendants filed a motion in support of the joint consent decree on October 13, 2023. (Doc. 32.) Plaintiffs filed a motion in support

of the joint consent decree on October 15, 2023. (Doc. 34.) The Court held a motions hearing on October 15, 2023, in Helena, Montana. (Doc. 35.) FACTUAL BACKGROUND This case involves challenges to Montana statutes House Bill 576 (“HB 576”)

and Senate Bill 392 (“SB 392”). HB 576 modifies the standards for evaluating whether “material damage” has occurred regarding water quality standards. (Doc. 21 at 20-21). SB 392 modifies the attorney’s fees and costs provision for claims

asserted under the Surface Mining Act. (Id. at 4); (id. at 23.) Plaintiffs claim that SB 392 and HB 576 modify the federally approved Montana Strip and Underground Mine Reclamation Act (SMURMA) program immediately, without the required

review and approval by relevant federal agencies. (Id. at 20.) Plaintiffs seek to enjoin Defendants from applying, effectuating, or enforcing any provisions of HB 576 or SB 392 unless and until they are first reviewed by federal agencies and the public

and approved by the U.S. Office of Surface Mining Reclamation and Enforcement (“OSMRE”) and the U.S. Environmental Protection Agency (“EPA”). (Id. at 27.) Plaintiffs also seek fees, costs, and other expenses provided by the Surface Mining Act. (Id.)

LEGAL BACKGROUND Plaintiffs and Defendants stipulated to a 210 day stay of the preliminary injunction proceedings, and agreed not to take any action to apply, effectuate, or

enforce HB 576 and SB 392 for the same 210 day period. (Doc. 9 at 3.) The Court approved the stipulation and stay on June 22, 2023. (Doc. 10.) The 210 day stay expires on January 18, 2024. DISCUSSION

The Court first will discuss the State’s motion to intervene. The Court will then consider Westmoreland’s motion to intervene. The Court will lastly consider the proposed consent decree. i. The State’s Motion to Intervene. Pursuant to Federal Rule of Civil Procedure 24(b), intervention may be allowed at the court’s discretion under the following conditions:

(1) a federal statute confers a conditional right to intervene; or (2) the applicant’s claim or defense and the main action involve a common question of fact of law; and (3) allowing intervention will not unduly delay or prejudice the adjudication of the original parties’ rights. Id. Permissive intervention must be timely, and in assessing timeliness, courts consider three factors: “the stage of the proceedings, the prejudice to existing parties, and the length of and reason for the delay.” League of United Latin Am. Citizens v. Wilson, 131 F.3d 1297, 1308 (9th Cir. 1997). In addition to the factors listed in the Federal Rule of Civil Procedure 24(b), the court may consider a number of other

factors: the nature and extent of the intervenors' interest, their standing to raise relevant legal issues, the legal position they seek to advance, and its probable relation to the merits of the case[,] whether changes have occurred in the litigation so that intervention that was once denied should be reexamined, whether the intervenors' interests are adequately represented by other parties, whether intervention will prolong or unduly delay the litigation, and whether parties seeking intervention will significantly contribute to full development of the underlying factual issues in the suit and to the just and equitable adjudication of the legal questions presented. Perry v. Schwarzenegger, 630 F.3d 898, 905 (9th Cir. 2011) (citation omitted). Permissive intervention rests in the sound discretion of the court. See Donnelly v. Glickman, 159 F.3d 405, 409 (9th Cir. 1998). The Court need not consider the elements set forth by the Ninth Circuit for intervention as a matter of right under Rule 24(a). See Wilderness Soc’y v. U.S.

Forest Serv., 630 F.3d 1173, 1177 (9th Cir. 2011). The Court, exercising its discretion under Rule 24(b), determines that the State has met the elements for permissive intervention. The State’s motion for intervention is timely. The

proceedings are at an early stage, as Plaintiffs filed their original complaint on June 1, 2023, and their amended complaint on September 11, 2023. (See Doc. 1); (Doc. 21.) The Court has not yet entered a scheduling order, and there is currently a 210 day stay against Defendants enforcing HB 576 or SB 392. (Doc. 10.)

The State’s defense involves a common question of fact and law: the validity of HB 576 and SB 392. The State seeks to advance a legal position not represented by the current parties: a substantive defense of HB 576 and SB 392. The State

contends that Defendants do not intend to offer a substantive defense of either statute. (Doc. 20 at 6-7.) The State’s presence in this action will ensure that the State’s interest in ensuring the validity of both statutes adequately will be represented. The State’s presence will not unduly delay the adjudication of the

original parties’ rights. Defendants are currently stayed from enforcing either HB 576 or SB 392 for 210 days. (See Doc. 10). The State indicates that it will not challenge the validity of the 210 day stay. (Doc. 20 at 15.) Plaintiffs admittedly may suffer prejudice if the Court permits the State to intervene. Confusion may arise if the Defendants, as state officials, and the State

disagree. Having one party of state officials, and one party as the State, may lead to inconsistent positions and a lack of clarity. To remedy this potential prejudice, the Court permits the State’s intervention on the condition that the State and Defendants

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Montana Environmental Information Center v. Montana Department of Environmental Quality, Counsel Stack Legal Research, https://law.counselstack.com/opinion/montana-environmental-information-center-v-montana-department-of-mtd-2023.