Atlantis Development Corp. v. United States

379 F.2d 818 (1967)

Quick Summary

The United States government (plaintiff) sued several companies (defendants) for unauthorized construction on the reefs off the Florida coast, which Atlantis Development Corporation, Ltd. (intervenor) claimed as the ‘Atlantis Group’. Atlantis, asserting ownership, sought to intervene, arguing that the outcome could affect its developmental rights.

The court denied Atlantis’s motion to intervene, but the appellate court reversed this decision, allowing Atlantis to intervene due to their significant stake in the property’s outcome.

Facts of the Case

The Atlantis Development Corporation, Ltd. (intervenor), a Bahamian company, claimed ownership of a group of islands off the Florida coast, which they had named the ‘Atlantis Group.’ After conducting explorations and planning to develop the reefs with facilities such as a fishing club and hotel, Atlantis sought to have its legal rights recognized and approached various government agencies.

The United States government (plaintiff) asserted control over the reefs, deeming them part of the Outer Continental Shelf and therefore under U.S. jurisdiction. This claim by the government led to a dispute with other companies (defendants) who were constructing structures on the reefs without permits, prompting legal action by the United States.

Procedural Posture and History

  1. The United States government filed a lawsuit against certain companies (defendants) for constructing structures on the reefs without proper authorization.
  2. Atlantis Development Corp. sought to intervene in the case, claiming ownership of the reefs and seeking to protect its interests.
  3. The district court denied Atlantis’s motion to intervene.
  4. Atlantis appealed the decision to the United States Court of Appeals for the Fifth Circuit.

I.R.A.C. Format


Whether Atlantis Development Corp. has a right to intervene in the lawsuit concerning the ownership and control of the reefs off the Florida coast.

Rule of Law

The provisions for mandatory intervention under Federal Rule of Civil Procedure 24(a), which allows intervention when an absentee may be practically affected by a disposition in a case.

Reasoning and Analysis

The appellate court considered whether the decision in the main lawsuit would practically impair or impede Atlantis’s ability to protect its claimed interests in the reefs. The court acknowledged that while the judgment between the government and defendants would not directly affect Atlantis’s rights, it would practically determine Atlantis’s claim against the government.

The court noted that Atlantis’s interest in the property was directly connected to the subject of the action and that a favorable ruling for the government would render Atlantis’s claims virtually worthless. The court concluded that under the revised Federal Rule of Civil Procedure 24(a), Atlantis should be allowed to intervene as a matter of right due to its significant stake in the outcome.


The appellate court reversed the district court’s decision, granting Atlantis Development Corp. the right to intervene in the lawsuit.

Key Takeaways

  1. Intervention as a matter of right under Federal Rule of Civil Procedure 24(a) can be based on practical impairment to an intervenor’s ability to protect their interest in a case.
  2. A party’s claim does not need to be proven at the intervention stage but must show a significant interest in the outcome of a case.
  3. The revised Federal Rules of Civil Procedure aim to allow broader participation in legal proceedings to ensure all interests are adequately represented and considered.

Relevant FAQs of this case

What factors are considered for a party to be granted intervention as a right under Federal Rule of Civil Procedure 24(a)?

A party seeking intervention as of right must demonstrate they have a legally protectable interest that may be impaired or impeded if intervention is denied, and existing parties are unlikely to adequately represent their interests.

  • For example: In a lawsuit challenging zoning changes, a homeowner within the affected area could seek mandatory intervention, arguing the outcome could limit the use of their property.

How does an interest in property factor into litigation involving government claims of jurisdiction?

Property interest plays a pivotal role when individuals or entities claim private rights that clash with government assertions of sovereignty or jurisdiction, prompting courts to scrutinize the validity of those claims.

  • For example: If a national park expansion plan overlaps with privately claimed land, the landowners’ property rights would become central in any legal dispute with the government over jurisdiction.

In what scenarios can the practical outcome of a lawsuit affect third parties not directly involved in the case?

Third parties may be affected by court decisions in lawsuits where judgments alter legal rights, set precedents impacting similar cases, or create binding agreements with industry-wide implications.

  • For example: Neighboring farmers might be impacted by a water rights dispute resolution between a state and a large agricultural corporation, as it could determine future water allocations for their own farming activities.


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