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Association of Data Processing Services v. Camp

Supreme Court of the United States · Constitutional Law

Constitutional LawStandingAdministrative LawJudicial Reviewstandinginjury in factzone of interestsAPA

Facts

Petitioners were companies that sold data processing services to businesses generally. They challenged a 1966 ruling of the Comptroller of the Currency stating that, incidental to banking services, a national bank could make available its data processing equipment or perform data processing services for other banks and bank customers. Petitioners alleged economic injury from this ruling, including that respondent American National Bank & Trust Company was performing or preparing to perform such services for two customers for whom petitioner Data Systems, Inc., had previously agreed or negotiated to perform the services. Petitioners claimed the ruling exceeded the lawful scope of national bank activities under the relevant banking statutes.

Issue

Whether competitors allegedly injured by the Comptroller's ruling had standing to sue in federal court, and whether judicial review of the Comptroller's action was available under the Administrative Procedure Act. More specifically, the question was whether petitioners needed to show a "legal interest" or instead only injury in fact and an interest arguably within the zone protected or regulated by the relevant statutes.

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. The existence of a "legal interest" goes to the merits, not standing. Judicial review under the Administrative Procedure Act is available unless statutes preclude review or the action is committed to agency discretion by law, and congressional intent to withhold review must be shown by clear and convincing evidence if not explicit.

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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 local businesses. The Federal Cooperative Finance Office issues a rule stating that federally chartered savings associations may offer payroll-processing services to their deposit customers, and Desert Ledger alleges that two longtime clients are considering switching because of the rule.

If Desert Ledger sues to challenge the agency rule, what is the strongest argument that it satisfies the standing requirement recognized by the Supreme Court?

Explanation. The majority held that standing requires an allegation of injury in fact, economic or otherwise, plus an interest arguably within the zone of interests protected or regulated by the relevant statute. Likely financial injury from agency-authorized competition is sufficient at the standing stage; the plaintiff need not first prove the rule is unlawful on the merits.