integration mandate is consistently met. Olmstead, 527 U.S. at 597-98 (“Because the Department is the agency directed by Congress to issue regulations implementing Title II, its views warrant respect.”) (citation omitted); see also M.R. v. Dreyfus, 663 F.3d 1100, 1117-18 (9th Cir. 2011). Accordingly, courts have allowed the United States to intervene in actions to enforce Olmstead, and the United States has also brought or participated in numerous other such actions across the country. In enacting the ADA, Congress sought “clear, strong, consistent, enforceable standards addressing discrimination against individuals with disabilities,” 42 U.S.C. § 12101(b)(2), and explicitly stated that one of the purposes of the ADA was “to ensure that the Federal Government plays a central role in enforcing the standards established [in the Act] on behalf of individuals with disabilities . . . .” Id. § 12101(b)(3). The central issues of this case are critical to the Department of Justice’s efforts to advance national goals of community integration and enforce the civil rights of persons with disabilities as required by the ADA. Thus, the United States meets this requirement for intervention as of right under Rule 24(a). Disposition of this Case May Impede the United States’ Interests The United States’ ability to protect its substantial legal interest would, as a practical matter, be impaired absent intervention. Federal decisions interpreting and applying the provisions of the Act are an important enforcement tool. The outcome of this case, including the potential for appeals by existing parties, implicates stare decisis concerns that warrant the United States’ intervention. See Day v. Apolonia, 505 F.3d 963, 965 (9th Cir. 2007) (intervention was necessary to protect state intervenor’s interest where case might “have a precedential impact regarding the availability of an enforceable right of action”); City of Los Angeles, 288 F.3d at 400 (amicus curiae status may be insufficient to protect rights of applicant for intervention
“because such status does not allow [applicant] to raise issues or arguments formally and gives [applicant] no right of appeal”); Smith, 651 F.2d at 1325 (“In appropriate circumstances, . . . stare decisis may supply the requisite practical impairment warranting intervention of right.”). As such, intervention is necessary to protect the United States’ substantial interest in this litigation. The Application for Intervention Is Timely In the Ninth Circuit, three factors are weighed in determining whether a motion for intervention is timely: “(1) the stage of the proceeding in which an applicant seeks to intervene; (2) the prejudice to other parties; and (3) the reason for and length of the delay.” County of Orange v. Air California, 799 F.2d 535, 537 (9th Cir. 1986) (citing United States v. Oregon, 745 F.2d 550, 552 (9th Cir. 1984)). “Mere lapse of time alone is not determinative.” Id. Rather, as the Supreme Court has emphasized, “[t]imeliness is to be determined from all the circumstances.” NAACP v. New York, 413 U.S. 345, 366 (1973); see also Day, 505 F.3d at 966 (granting state intervenor’s motion where it could not “be said that the state ignored the litigation or held back from participation to gain tactical advantage[,]” and noting that “all the circumstances of the case must be considered in ascertaining whether or not a motion to intervene is timely[.]”) (quoting Legal Aid Soc’y of Alameda County v. Dunlop, 618 F.2d 48, 50 (9th Cir. 1980)). In this case, all three prongs of the timeliness analysis weigh in favor of granting the United States’ intervention motion. First, this motion is being filed at a sufficiently early stage of the proceeding because the district court has not yet “substantively — and substantially — engaged the issues in [the] case.” League of United Latin Am. Citizens v. Wilson (LULAC), 131 F.3d 1297, 1303 (9th Cir. 1997). Here, the Court granted a motion by Defendants to dismiss, but