What Interest You Must Have to Be Allowed to Participate In a Legal Proceeding ?
In Maillie v. Greater Delaware Valley Health Care, Inc., 156 Pa. Commw. 582, 628 A.2d 528 (Pa. Cmwlth. 1993), the Court addressed what interest a party must have to be entitled to participate in a proceeding. Citing William Penn Parking Garage, Inc. v. City of Pittsburgh, 464 Pa. 168, 346 A.2d 269 (1975), the Court explained:
"The test for standing is that a party must have a direct interest in the subject matter of the litigation, which must be substantial and immediate, rather than a remote consequence of the judgment." Id. at 532.
"A person who is not adversely affected in any way by the matter he seeks to challenge is not 'aggrieved' thereby and has no standing to obtain a judicial resolution of this challenge. Id. at 192, 346 A.2d at 280
A party 'must show a sufficiently close causal connection between the challenged action and the asserted injury to qualify the interest as 'immediate' rather than 'remote.' Id. at 202, 346 A.2d at 286." Maillie, 628 A.2d at 532.
In Maillie, the Court held that subscribers of an HMO did not have standing to bring a class action against the HMO's directors who allegedly used their positions to become unjustly enriched by converting the HMO from a non-profit to a for-profit corporation and then purchasing it for insufficient consideration and reselling it for profit.
Noting that there was no evidence that any class member suffered any harm, let alone immediate harm, we stated that just because there was an allegation that the defendants might have been unjustly enriched, it was not a linking factor between the class and its health insurance coverage - "the only benefit to which the class was entitled." Id. at 592.