Milford v. Local

In Milford v. Local 1566, 200 Conn. 91, 94, 510 A.2d 177 (1986), a significant case in which the intervenor had no direct interest in the judgment as between the two parties to the litigation and was allowed to intervene. The intervenor was the state board of mediation and arbitration, and the case involved the vacation of an arbitration award in an employment dispute, the outcome of which was of no interest to the board. The intervention was granted to allow the board to defend the validity of its arbitration procedures. The motion of the board in the trial court did not indicate whether it sought intervention as of right or permissively, and our Supreme Court upheld the action as a permissive intervention, pursuant to rule 24 (b). It used, the same four criteria as federal and state cases use for intervention as of right pursuant to rule 24 (a). Id., 94. It also used the criteria of prejudice to the existing parties and the necessity or value of the intervention in terms of resolving the controversy. The court, in its reasoning to establish standing of the board to intervene, used an aggrievement test, that is, whether the board had a specific personal and legal interest that would be specially and injuriously affected by the decision. Id., 96.