Pittman v. Veolia North America, Inc., et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
RAYMOND PITTMAN
VERSUS
VEOLIA NORTH AMERICA, INC.,
ET AL.
CIVIL ACTION
NO. 24-2891
SECTION "H" (3)
ORDER AND REASONS
Before the Court is the motion of Blue Hill Specialty Insurance Company
(“Blue Hill”) to intervene in this matter (R. Doc. 36) pursuant to Rule 24(b)(1)(B) of
the Federal Rules of Civil Procedure. The deadline to oppose the motion has expired,
and no opposition was filed.
“Plaintiff Raymond Pittman brought suit in the Civil District Court for the
Parish of Orleans against Veolia North America, Inc. and several related entities for
injuries he sustained in an explosion at Veolia Water Treatment Plant.”1 The Veolia
entities then filed a third-party complaint against CFR Trucking, LLC, the alleged
employer of Plaintiff.2 CFR Trucking, LLC, had an insurance policy from Blue Hillthe
period of which included the date of the accident.3 Blue Hill now seeks to intervene
to obtain a declaratory judgment as to that policy’s potential coverage in connection
with this matter.
1 R. Doc. at 17 at 1.
2 E.g., R. Doc. 25 at 1.
3 R. Doc. 36-3, ¶ 13.
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Movants seek permissive intervention under Rule 24(b). As relevant here, Rule
24(b) provides:
On timely motion, the court may permit anyone to intervene who ... has
a claim or defense that shares with the main action a common question
of law or fact ... [i]n exercising its discretion, the court must consider
whether the intervention will unduly delay or prejudice the adjudication
of the original parties’ rights.
Thus, courts have considerable discretion in determining whether to allow
permissive intervention. See, e.g., Louisiana v. Burgum, 132 F.4th 918, 923–24 (5th
Cir. 2025).
Courts engage in a two-step inquiry when analyzing
permissive intervention. Stallworth v. Monsanto Co., 558 F.2d 257, 269 (5th Cir.
1977). First, the court decides whether the proposed intervenor’s claim or defense and
the underlying suit possess a common question of law or fact. Id. If so, then the court
“must exercise its discretion in deciding whether intervention should be allowed.” Id.
Blue Hill satisfies both aspects of this inquiry. First, Blue Hill’s claim shares common
questions of fact or law with the existing action. Second, discretion counsels in favor
of permitting amendment on this record. Allowing Blue Hill to intervene will ensure
its participation in the upcoming telephone status conference with the District Court,
and there is no allegation that Blue Hill’s motion is untimely. Further, intervention
will not unduly delay or prejudice adjudication of this matter. To the contrary,
allowing intervention will contribute to judicial efficiency and the development of the
litigation.
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Accordingly,
IT IS ORDERED that the Motion to Intervene (R. Doc. 36) is GRANTED and
that Blue Hill’s proposed pleading (R. Doc. 36-3) be filed in the record.
New Orleans, Louisiana, this 2 nd day of April, 2026.
EVA J. DOSSIER
UNITED STATES MAGISTRATE JUDGE
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