Association of Data Processing Service Organizations, Inc. v. Camp

Supreme Court of the United States · 1970 · Administrative Law

Administrative LawFederal CourtsStandingJudicial Review under the APAstandinginjury in factzone of interestsAPA

Facts

Petitioners were sellers of data processing services to businesses and challenged a 1966 ruling by the Comptroller stating that, incidental to banking services, a national bank could make its data processing equipment or services available to other banks and bank customers. Petitioners alleged that this ruling caused them economic injury because national banks would compete with them and because respondent American National Bank & Trust Company was performing or preparing to perform services for two customers for whom petitioner Data Systems, Inc. had previously agreed or negotiated to provide services. Petitioners sued both the bank and the Comptroller. They claimed the ruling exceeded authority under the relevant banking statutes.

Issue

Whether competitors allegedly injured by the Comptroller's ruling had standing to seek judicial review in federal court, and whether review of the Comptroller's action was precluded. More specifically, the question was whether petitioners' economic injury and statutory relationship to the banking laws were sufficient under Article III and the APA.

Rule

For standing, the plaintiff must allege injury in fact, economic or otherwise, and the interest sought to be protected must be arguably within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question. Under the APA, judicial review is available to a person aggrieved by agency action within the meaning of a relevant statute unless statutes preclude review or the action is committed to agency discretion by law; preclusion of review requires clear and convincing evidence of congressional intent.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Desert Ledger LLC sells payroll-processing services to small retailers. The Federal Financial Licensing Bureau issues an interpretive ruling allowing federally chartered savings institutions to sell payroll-processing services to nonbank business customers, and Desert Ledger alleges that two longtime clients have begun negotiating with Copper Mesa Savings because of the ruling.

If Desert Ledger sues the Bureau under the APA to challenge the ruling, what is the strongest basis for finding Article III standing under the majority's approach?

Explanation. The majority held that standing begins with whether the plaintiff alleges injury in fact, economic or otherwise. Allegations of likely financial injury from new competition, especially where specific customers are being solicited or shifted, are sufficient at the standing stage. The plaintiff need not first prove the agency is wrong on the merits, and the Court rejected a blanket rule either granting or denying standing to all competitors. (Derived from Association of Data Processing Service Organizations, Inc. v. Camp (1970).)