N.M. R. Civ. P. Dist. Ct. 1-024
In exercising its discretion pursuant to this paragraph the court shall consider whether the intervention will unduly delay or prejudice the adjudication of the rights of the original parties.
N.M. R. Civ. P. Dist. Ct. 1-024
ANNOTATIONS The 1995 amendment, effective July 1, 1995, made gender neutral changes in Subparagraph A(2), added the last sentence in Paragraph C, and deleted former Paragraph D, which provided for simplified intervention by members of a class.
For joinder of parties, see Rules 1-019 and 1-020 NMRA. For class actions, see Rule 1-023 NMRA. For intervention in suit on bond of public contractor, see Section 13-4-19 NMSA 1978. For intervention in partition proceedings, see Section 42-5-4 NMSA 1978. For intervention by attorney in quiet title action, see Section 42-6-10 NMSA 1978. For intervention in attachment proceedings, see Section 42-9-29 NMSA 1978. Compiler's notes. - This rule is deemed to have superseded 105-1501 to 105-1503, C.S. 1929, which were substantially the same as Paragraphs A to C. Timeliness of motion to intervene. - Intervenor's motion to intervene was not timely and was properly denied, even if the intervenor had a right to intervene, where the intervenor's president was made aware of the pending litigation four months after the complaint was filed and intervenor did not file a motion to intervene for more that sixteen months after the complaint was filed. Nellis v. Mid-Century Ins. Co., 2007 -NMCA-090, 142 N.M. 115, 163 P.3d 502. Statutory authorization required. - Intervention under Paragraph A(1) of this rule is not allowed in the absence of direct statutory authorization. Wilson v. Massachusetts Mutual Life Ins. Co., 2004 -NMCA-051, 135 N.M. 506, 90 P.3d 525, cert. denied, 2004-NMCERT-004. Federal courts applying federal counterpart to this rule have granted intervention where a statute provides for such intervention. Wilson v. Massachusetts Mutual Life Ins. Co., 2004 -NMCA-051, 135 N.M. 506, 90 P.3d 525, cert. denied, 2004-NMCERT-004. Intervention defined. - Intervention is an act or proceeding whereby a person is permitted to become a party in an action between other persons, after which the litigation proceeds with the original and intervening parties. Richins v. Mayfield, 1973-NMSC-099, 85 N.M. 578, 514 P.2d 854; State ex rel. Attorney Gen. v. Reese, 1967-NMSC-172, 78 N.M. 241, 430 P.2d 399. Where trust beneficiaries were effectively accorded the rights to object under Rule 1-023.1 NMRA, any error the trial court might have made in interpreting the beneficiaries' objection as a motion to intervene would not have changed the result. In re Norwest Bank of N.M., N.A., 2003-NMCA-128, 134 N.M. 516, 80 P.3d 98, cert. denied, 2003-NMCERT-002. Parties on same side of suit remain separate. - These rules, as well as the common understanding of what is meant by a party to a lawsuit, are inconsistent with the position that all parties on one side of a lawsuit are but one party. Romero v. Felter, 1972-NMSC-032, 83 N.M. 736, 497 P.2d 738. Timeliness circumstantially determined. - Just when an application to intervene is timely must depend on the circumstances of each case. Tom Fields, Ltd. v. Tigner, 1956-NMSC-083, 61 N.M. 382, 301 P.2d 322. A key consideration in determining timeliness of intervention is whether the effort to intervene occurred shortly after the would-be intervenor discovered such action was necessary to protect its interests. Thriftway Mktg. Corp. v. State, 1990-NMCA-115, 111 N.M. 763, 810 P.2d 349. A crucial factor in determining if motion to intervene is timely is whether the intervenor knew of its interest and could have sought to intervene earlier in the proceedings. In re Norwest Bank of N.M., N.A., 2003-NMCA-128, 134 N.M. 516, 80 P.3d 98, cert. denied, 2003-NMCERT-002. Prejudice as factor in timeliness determination. - The trial court must consider whether permitting intervention will prejudice the existing parties, particularly with respect to additional delay. Where the litigation is of great complexity, permitting intervention may be more prejudicial to existing litigants. In re Norwest Bank of N.M., N.A., 2003-NMCA-128, 134 N.M. 516, 80 P.3d 98, cert. denied, 2003-NMCERT-002. Within discretion of trial court. - Timeliness is a threshold requirement for intervention and the timeliness of an application for intervention depends upon the circumstances of each case as timeliness is a matter peculiarly within the discretion of the trial court. Apodaca v. Town of Tome Land Grant, 1974-NMSC-026, 86 N.M. 132, 520 P.2d 552. Assuming that the trust beneficiaries' challenge to the settlement agreement constituted a motion to intervene and that the beneficiaries were entitled to the leeway given to intervenors as of right, there was no abuse of discretion in the trial court's refusal to permit intervention where the beneficiaries were given ample opportunity to become parties before the trial, were given timely notice of the trial, and chose not to intervene to protect their interests. In re Norwest Bank of N.M., N.A., 2003-NMCA-128, 134 N.M. 516, 80 P.3d 98, cert. denied, 2003-NMCERT-002. Where the intervenors have presented no factual basis whatsoever to support their argument that they did not know of their interest and could not have intervened at an earlier time, the intervenors did not meet their threshold burden of showing that their motion to intervene was timely, and therefore, the district court did not abuse its discretion in finding that the intervenors' motion to intervene was untimely. Murken v. Solv-Ex Corp., 2005-NMCA-137, 138 N.M. 653, 124 P.3d 1192. Court may scrutinize complaint for a cause of action. - While a determination that a proposed complaint in intervention is legally sufficient - so as to withstand a motion to dismiss for failure to state a claim under Paragraph B(6) of Rule 1-012 NMRA - is not required before the trial court may grant an application to intervene, it is certainly permissible for the court to scrutinize the proffered complaint to see whether it states a cause of action. Solon ex rel. Ponce v. WEK Drilling Co., 1992-NMSC-023, 113 N.M. 566, 829 P.2d 645. Exercise governed by equitable principles. - The timeliness of such an application depends upon the circumstances of each case, and in the absence of a specific statutory provision fixing the time within which the right to intervene must be exercised, the timeliness is governed by equitable principles. Richins v. Mayfield, 1973-NMSC-099, 85 N.M. 578, 514 P.2d 854. Undue delay considered. - An intervening party may not demand time to file intervention petition if granting such time would delay hearing. Clark v. Rosenwald, 1925-NMSC-062, 31 N.M. 443, 247 P. 306 (decided under former law). Generally, intervention must take place while action is pending and will not be permitted after commencement of trial; therefore, it is the general rule that intervention will not be allowed after a final judgment or decree has been entered. Richins v. Mayfield, 1973-NMSC-099, 85 N.M. 578, 514 P.2d 854. Generally, a motion to intervene will not be granted after a final judgment has been entered, absent unusual circumstances, but it should not be automatically denied. Nesbit v. City of Albuquerque, 1977-NMSC-107, 91 N.M. 455, 575 P.2d 1340. Discretion to deny intervention of right carefully exercised. - Intervention will not normally be allowed after trial has commenced; however, trial courts should be more circumspect in their exercise of discretion when the intervention is of right rather than permissive. Apodaca v. Town of Tome Land Grant, 1974-NMSC-026, 86 N.M. 132, 520 P.2d 552. Unclaimed Property Act. - Since there is an absence of any specific authority for intervention in New Mexico's Unclaimed Property Act, such a right under Paragraph A(1) of this rule is not recognized. Wilson v. Massachusetts Mutual Life Ins. Co., 2004 -NMCA-051, 135 N.M. 506, 90 P.3d 525, cert. denied, 2004-NMCERT-004. Where certificates awarded to policyholders in class action suit settlement are not property under the Unclaimed Property Act, New Mexico failed to establish that it had an interest in the settlement necessary for intervention under Paragraph A(2) of this rule. Wilson v. Massachusetts Mutual Life Ins. Co., 2004 -NMCA-051, 135 N.M. 506, 90 P.3d 525, cert. denied, 2004-NMCERT-004. Intervention improper in settled matter. - This rule concerns intervention on timely application and relates to those situations where the question in controversy is pending and has not been settled, therefore intervention order subsequent to mandamus and levy of tax is improper. Speer v. Sierra County Comm'rs, 1969-NMSC-154, 80 N.M. 741, 461 P.2d 156. Denial proper after commencement of complex trial. - Denial of application for intervention where such application was not filed until four and one-half years after complex litigation started involving numerous parties, much pretrial discovery and a number of motions and indeed not until after the trial had started, was not an abuse of discretion. Apodaca v. Town of Tome Land Grant, 1974-NMSC-026, 86 N.M. 132, 520 P.2d 552. Full opportunity to present claim, though motion denied. - The court essentially allowed a party to intervene, since it heard her claims and allowed her to fully develop her case before the court. She did obtain a full hearing of her claims, and the court did not abuse its discretion in denying her motion to intervene. Ruybalid v. Segura, 1988-NMCA-084, 107 N.M. 660, 763 P.2d 369. Intervention after default. - An uninsured motorist insurer's intervention in an action by its insured against the uninsured motorist after the insurer learned of the entry of a default judgment against the uninsured motorist was not untimely since, until the default, the insurer's interests could have been adequately represented by the uninsured motorist. Burge v. Mid-Continent Cas. Co., 1997 -NMSC-009, 123 N.M. 1, 933 P.2d 210. Intervention untimely after announcement of decision. - Where judgment creditor attempts to intervene in suit to foreclose chattel mortgage after trial has concluded and court has announced its decision and called for requested findings from parties, petition is untimely and denial thereof is not abuse of discretion. Tom Fields, Ltd. v. Tigner, 1956-NMSC-083, 61 N.M. 382, 301 P.2d 322. Intervention after verdict improper for spurious class members. - Intervention by members of a spurious class after a verdict by the jury is not allowed absent extraordinary or unusual circumstances. Absent said circumstances, granting intervention is an abuse of discretion. Valley Utils., Inc. v. O'Hare, 1976-NMSC-024, 89 N.M. 262, 550 P.2d 274. Intervention can be timely after trial. - Municipal judge does not waive his right to intervene where, in action to force his recall election, he has filed as amicus curiae but, believing his interests to be protected by defendant city commission and by filing as amicus curiae, does not seek to intervene until after trial when district court announces its intended decision, but before it renders a final judgment, at which time judge learns that city commission did not intend to appeal from announced adverse ruling. The judge is allowed to intervene at that point since his interests are no longer protected by city commission. Cooper v. Albuquerque City Comm'n, 1974-NMSC-006, 85 N.M. 786, 518 P.2d 275. Where intervention sole means to protect right. - In certain instances intervention will be allowed, even after a final judgment where it is necessary to preserve a right which cannot otherwise be protected; hence, the trial judge must find that the right or interest cannot otherwise be protected, except by intervention. Richins v. Mayfield, 1973-NMSC-099, 85 N.M. 578, 514 P.2d 854. Intervention after final judgment. - An attempt to intervene after final judgment has been issued by the district court should not be allowed in the absence of extraordinary or unusual circumstances. Thriftway Mktg. Corp. v. State, 1990-NMCA-115, 111 N.M. 763, 810 P.2d 349. Intervention on appeal authorized. - Where the plaintiff in error did not make taxpayers who were real parties in interest defendants, they may be permitted to intervene in an appeal by one aggrieved by the action of the city council in refusing to fund warrants issued by the city and unpaid. Miller v. City of Socorro, 1898-NMSC-019, 9 N.M. 416, 54 P. 756 (decided under former law). Intervention may be allowed even at the appellate level in appropriate cases. Thriftway Mktg. Corp. v. State, 1990-NMCA-115, 111 N.M. 763, 810 P.2d 349. Intervention on appeal was timely filed. - Indian tribe political chapter's motion to intervene on appeal in a liquor license transfer case was timely filed, where the proposed transfer site was located within the geographical boundaries of the chapter, and the chapter wished to argue on behalf of the state's position on appeal. Thriftway Mktg. Corp. v. State, 1990-NMCA-115, 111 N.M. 763, 810 P.2d 349. Intervention as party-plaintiff by defendant insurer conditionally authorized. - An insurance company, claiming a right to reimbursement for funds expended, can intervene as a party-plaintiff when the same company is the insurance carrier for the defendants only under such conditions as would properly protect all the parties to the litigation. To protect the parties, the intervention should not be made final until the main case is ready for judgment. In the interim the company is precluded from participating as a party-plaintiff. Varney v. Taylor, 1963-NMSC-036, 71 N.M. 444, 379 P.2d 84, criticized, Herrera v. Springer Corp., 1973-NMCA-041, 85 N.M. 6, 508 P.2d 1303. Sufficiency of interest circumstantially determined. - An interest to permit intervention must be determined from the facts in each case. Stovall v. Vesely, 1934-NMSC-055, 38 N.M. 415, 34 P.2d 862 (decided under former law). Interests of intervenor in litigation must be direct, not contingent. First Nat'l Bank v. Clark, 1915-NMSC-083, 21 N.M. 151, 153 P. 69, 1916C L.R.A. 33(1915); see also Gomez v. Ulibarri, 1918-NMSC-070, 24 N.M. 562, 174 P. 737; C.J.L. Meyer & Sons Co. v. Black, 1888-NMSC-005, 4 N.M. (Gild.) 352, 16 P. 620; Field v. Sammis, 1903-NMSC-013, 12 N.M. 36, 73 P. 617; Baca v. Anaya, 1908-NMSC-009, 14 N.M. 382, 94 P. 1017 (decided under former law). In order to establish an interest in the pending action a party seeking to intervene must show that it has an interest that is significant, direct rather than contingent, and based on a right belonging to the proposed intervenor rather than an existing party to the suit. Cordova v. State ex rel. Human Servs. Dep't, 1989-NMCA-110, 109 N.M. 420, 785 P.2d 1039. Because the county treasurer's motion to intervene alleged only a general interest in the litigation and did not allege nonfeasance or other improper conduct on the part of the director or the division in valuing the property involved herein, nor raised any issue concerning nondisbursement or the improper disbursement of funds derived from tax assessments levied against mining properties or property used in connection therewith, the county treasurer failed to overcome the presumption of adequacy of representation in actions by property owners against the Director of the Property Tax Division of the State Department of Taxation and Revenue. Chino Mines Co. v. Del Curto, 1992-NMCA-108, 114 N.M. 521, 842 P.2d 738. Interests of persons as taxpayers and as representatives of the potential life of the unborn did not entitle them to intervene in a suit challenging the contitutionality of a rule of the human services department prohibiting state funding for certain abortions. New Mexico Right to Choose/NARAL v. Johnson, 1999-NMSC-005, 126 N.M. 788, 975 P.2d 841, cert. denied, 526 U.S. 1020, 119 S. Ct. 1256, 143 L. Ed. 2d 352 (1999). Where intervening party raises same questions of fact and law. - Decision to permit intervention by state was within the court's discretion where the state's complaint raised the same questions of fact and law under the New Mexico Subdivision Act that were raised in the county's complaint seeking redress for violation of the Act. State ex rel. Stratton v. Alto Land & Cattle Co., 1991-NMCA-146, 113 N.M. 276, 824 P.2d 1078. Prima facie showing of interest insufficient for intervention. - In an action under 41-2-3 NMSA 1978, an alleged natural father established a prima facie showing of an interest but failed to make a showing of inadequate representation by the child's mother that would warrant his intervention. Dominguez v. Rogers, 1983-NMCA-135, 100 N.M. 605, 673 P.2d 1338. Denial of intervention improper where there is no basis to preclude intervention. - Where Petitioner sought to intervene in wrongful death action on behalf of the illegitimate child of the decedent, the district court erred in denying Petitioner's motion to intervene when there was no basis to preclude Petitioner's intervention to pursue the child's individual loss of consortium claim. Spoon v. Mata, 2014-NMCA-115. Judgment and independent equitable proceedings not required to intervene. - A creditor may file an intervening petition where a debtor's funds are in custodia legis to have funds applied to his claim, independent proceedings in equity not being required; his claim need not have been first reduced to judgment. Fuqua v. Trego, 1943-NMSC-004, 47 N.M. 34, 133 P.2d 344. Intervention not conditioned on prior consideration of claim. - Petitioners, as to any interest which they might have in premises sought to be foreclosed, where they are not made party defendants, are entitled reasonably to intervene to assert and protect such interest, and need not move for an early consideration of their petition in order to preserve their rights. State ex rel. Lebeck v. Chavez, 1941-NMSC-016, 45 N.M. 161, 113 P.2d 179 (decided under former law). Foster parents failed to establish a basis for intervention as a matter of right in proceedings to terminate the rights of the natural parents, where their motion did not comply with the requirements of Paragraph C, or adequately apprise the children's court of the claims sought to be raised by intervention. Cordova v. State ex rel. Human Servs. Dep't, 1989-NMCA-110, 109 N.M. 420, 785 P.2d 1039. Orders denying intervention deemed final. - Orders denying applications to intervene, whether permissive or as of right, are final orders and thus appealable. Apodaca v. Town of Tome Land Grant, 1974-NMSC-026, 86 N.M. 132, 520 P.2d 552. Timely objection required for relief from irregular intervention proceedings. - Intervention proceedings quite obviously not in conformity with this rule, in that no written motion is ever served and that intervention is granted solely on oral motion on the day of trial, are not grounds for a new trial absent timely objection at trial. New Mexico Selling Co. v. Cresenda Corp., 1964-NMSC-180, 74 N.M. 409, 394 P.2d 260. An order denying intervention is fundamentally interlocutory, although it is deemed final for purposes of allowing it to be immediately appealed. Appeal of order denying intervention does not divest district court of jurisdiction over the merits of the case. Murken v. Solv-Ex Corp., 2006-NMCA-064, 139 N.M. 625, 136 P.3d 1035. Law reviews. - For article, "Attachment in New Mexico - Part II," see 2 Nat. Resources J. 75 (1962). For article, "The Impact of the Revised New Mexico Class Action Rules Upon Consumers," see 9 N.M.L. Rev. 263 (1979). For comment, "Statutory Notice in Zoning Actions: Nesbit v. City of Albuquerque," see 10 N.M.L. Rev. 177 (1979-80). For note, "Title Insurance - New Mexico Sets the Date for Determination of Value in Title Insurance Cases: Hartman v. Shambaugh," see 12 N.M.L. Rev. 833 (1982). For note, "Family Law - A Limitation on Grandparental Rights in New Mexico: Christian Placement Service v. Gordon," see 17 N.M.L. Rev. 207 (1987). For article, "Statutory Adoption of Several Liability in New Mexico: A Commentary and Quasi-Legislative History," see 18 N.M.L. Rev. 483 (1988). For article, "The Impact of Non-Mutual Collateral Estoppel on Tort Litigation Involving Several Liability," see 18 N.M.L. Rev. 559 (1988). For article, "Supplemental Jurisdiction over Claims in Intervention," see 23 N.M.L. Rev. 57 (1993). Am. Jur. 2d, A.L.R. and C.J.S. references. - 8 Am. Jur. 2d Automobiles and Highway Traffic §1045; 14 Am. Jur. 2d Carriers §1135; 19 Am. Jur. 2d Corporations §§2235 to 2242; 2407 to 2417; 59 Am. Jur. 2d Parties §124 et seq. Corporation having name similar to proposed name as entitled to intervene in proceeding by other corporation for change of name, 72 A.L.R.3d 8. Assertion of fiduciary status of parties to litigation as basis for intervention by one claiming beneficial interest as trust beneficiary, 2 A.L.R.2d 227. Right of defendant in action for personal injury or death to bring in joint tort-feasor for purpose of asserting right of contribution, 11 A.L.R.2d 228, 95 A.L.R.2d 1096. Appealability of order granting or denying right of intervention, 15 A.L.R.2d 336. Right of retailer sued by consumer for breach of implied warranty of wholesomeness or fitness of food or drink, to bring in as a party defendant the wholesaler or manufacturer from whom the article was procured, 24 A.L.R.2d 913. Intervention by stockholder for purpose of interposing defense for corporation, 33 A.L.R.2d 473. Time within which right to intervene may be exercised, 37 A.L.R.2d 1306. Right to intervene in court review of zoning proceeding, 46 A.L.R.2d 1059. Dismissal of plaintiff's case for want of prosecution as affecting defendant's counterclaim, setoff, or recoupment or intervener's claim for affirmative relief, 48 A.L.R.2d 748. Right of adjoining landowners to intervene in condemnation proceedings on ground that they might suffer consequential damage, 61 A.L.R.2d 1292. Intervention by other stockholders in stockholder's derivative action, 69 A.L.R.2d 562. Right of attorney general to intervene in will contest case involving charitable trust, 74 A.L.R.2d 1066. When is representation of applicant's interest by existing parties inadequate and applicant bound by judgment so as to be entitled to intervention as of right under Federal Rule 24(a)(2) and similar state statutes or rules, 84 A.L.R.2d 1412. Discretionary intervention in action between union and union member, 93 A.L.R.2d 1037. Loan receipt or agreement between insured and insurer for a loan repayable to extent of recovery from other insurer or carrier or other person causing loss, 13 A.L.R.3d 42. Similar frauds practiced on various persons as basis of representative suit, 53 A.L.R.3d 534. Bringing in or intervention of third person in suit for divorce which involves property rights, 63 A.L.R.3d 373. Existence and extent of right of litigant in civil case, or of criminal defendant, to represent himself before state appellate courts, 24 A.L.R.4th 430. Timeliness of application to intervene made under Rule 24 of Federal Rules of Civil Procedure after denial of class certification for intervenors, 46 A.L.R. Fed. 864. Timeliness of application for intervention as of right under Rule 24(a) of Federal Rules of Civil Procedure, 57 A.L.R. Fed. 150. Employee's right to intervene in federal judicial proceeding concerning labor arbitration, 59 A.L.R. Fed. 733. What is "interest" relating to property or transaction which is subject of action sufficient to satisfy that requirement for intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure, 73 A.L.R. Fed. 448. When is interest of proposed intervenor inadequately represented by existing party so as to satisfy that requirement for intervention as of right under Rule 24(a)(2) of Federal Rules of Civil Procedure, 74 A.L.R. Fed. 327. General considerations in determining what constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure, 74 A.L.R. Fed. 632. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in employment discrimination actions, 74 A.L.R. Fed. 895. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving disclosure of information, 75 A.L.R. Fed. 145. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions relating to school desegregation, 75 A.L.R. Fed. 231. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions relating to securities and commodities laws, 75 A.L.R. Fed. 426. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving government-supported housing and welfare programs, 75 A.L.R. Fed. 570. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving contracts, 75 A.L.R. Fed. 769. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving insurance, 75 A.L.R. Fed. 869. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in personal injury or death actions, 76 A.L.R. Fed. 174. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in zoning and other actions relating to real property, 76 A.L.R. Fed. 388. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions relating to banks and banking, 76 A.L.R. Fed. 546. What constitutes impairment of attorney's interest in his fee to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure, 76 A.L.R. Fed. 639. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in environmental actions, 76 A.L.R. Fed. 762. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions relating to patents, copyrights, and trademarks, 76 A.L.R. Fed. 837. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in labor actions, 77 A.L.R. Fed. 201. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving energy, 77 A.L.R. Fed. 541. What constitutes impairment of proposed intervenor's interest to support intervention as a matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in antitrust actions, 78 A.L.R. Fed. 385. What constitutes impairment of proposed intervenor's interest to support intervention as a matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving ships and shipping, 78 A.L.R. Fed. 630. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving government food and drug regulations, 80 A.L.R. Fed. 907. What constitutes impairment of proposed intervenor's interest to support intervention as matter of right under Rule 24(a)(2) of Federal Rules of Civil Procedure in actions involving bankruptcy, 82 A.L.R. Fed. 435. Right to intervene in federal hazardous waste enforcement action, 100 A.L.R. Fed. 35. When is intervention as matter of right appropriate under Rule 24(a)(2) of Federal Rules of Civil Procedure in civil rights action, 132 A.L.R. Fed. 147. Construction and application of 28 USCA §2403 (and similar predecessor provisions), concerning intervention by United States or by state in certain federal court cases involving constitutionality of statutes, 147 A.L.R. Fed. 613. 67A C.J.S. Parties §§ 68 to 87.