Village Road Coal. v. Teton County Hous. Auth.
Annotate this CaseIn 2006, Teton County voters approved a Teton County Housing Authority (TCHA) sponsored ballot initiative enabling a specific purpose excise tax (SPET) to raise $5 million for TCHA's affordable housing program. In 2007, TCHA purchased a five-acre property on Cheney Lane. Later that year, Plaintiffs, residents of the Cheney Lane neighborhood, initiated a declaratory judgment action against TCHA, alleging violations of SPET limitations, breach of investment duties, and violations of Wyoming statutory limits on public financing. Two weeks after the district court heard arguments on the motion to dismiss, the Village Road Coalition (VRC), a nonprofit corporation consisting of residents of a neighborhood near the Cheney Lane property, filed a motion to intervene. The district court denied the motion. The court subsequently granted TCHA's motion to dismiss the complaint for lack of standing. The Supreme Court affirmed, holding (1) because VRC's interests and relief sought were duplicative of those presented by Plaintiffs, the district court did not err in denying the motion to intervene; and (2) the district court properly dismissed TCHA's action for lack of standing, as Plaintiffs failed to allege a tangible interest that had been harmed by the acquisition of the property.
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