The Oyez Project: Judicial Power Issues - Statutory Standing Decisions

Air Courier Conference v. Postal Workers

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Anza v. Ideal Steel Supply Corporation

Can a competitor be "injured in his business or property by reason of a violation" of the Racketeer Influenced and Corrupt Organizations Act (RICO) when the competitor is not the party defrauded and did not rely on the fraudulent behavior, but claims to have lost a competitive advantage because of the fraud?

No. Eight members of the Supreme Court agreed that Ideal did not have standing to bring the suit because the relationship between its injuries and the fraudulent conduct of National was too remote. Justice Anthony Kennedy, writing for a seven-member majority, wrote that "[w]hen a court evaluates a RICO claim for proximate causation, the central question it must ask is whether the alleged violation led directly to the plaintiff's injuries. In the instance case, the answer is no." Justice Stephen Breyer wrote separately to say that the decisive factor in this case was not just the indirectness of the injury but also the fact that legitimate business practices (the lowering of prices) had actually caused it, even though those practices were made possible by the fraud. The ninth member - Justice Clarence Thomas - wrote that while he disagreed with the other justices' concern about directness, he too would have ruled in National's favor because the case had nothing to do with organized crime, RICO's original target.

Bennett v. Spear

Can private parties who claim they have suffered economic harm from enforcement of the Endangered Species Act sue to reverse regulation?

Yes. In the unanimous decision, announced by Justice Antonin Scalia, the Court ruled that the petitioners had standing to ask for judicial review of the minimum water level setting under the Endangered Species Act. The Act explicitly allows "any person" to sue the government over an alleged violation. Justice Scalia asserted this applies to the Secretary's actions over enforcement.

Director, Office Of Workers' Compensation Programs, Department Of Labor v. Newport News Shipbuilding & Dry Dock Co.

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Gladstone, Realtors v. Village Of Bellwood

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Gollust v. Mendell

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Hardin v. Kentucky Utilities Co.

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Havens Realty Corp. v. Coleman

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Holmes v. Securities Investor Protection Corporation

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Jackson Transit Authority v. Transit Union

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National Credit Union Administration v. First National Bank

Do banks and professional associations have standing under the Administrative Procedure Act to seek federal-court review of the National Credit Union Administration's decisions? Is the NCUA's interpretation of section 109 of the Federal Credit Union Act permissible?

Yes and no. In a 5-4 opinion delivered by Justice Clarence Thomas, the Court held that banks and professional associations have prudential standing under the APA to seek federal-court review of the NCUA's interpretation of section 109. By the same majority, the Court also held that the NCUA's interpretation of section 109, under which a common bond of occupation must unite only the members of each unrelated employer group, is impermissible. After concluding that the banks and professional associations' interests fall within the "zone of interests" protected by section 109, Justice Thomas wrote that the NCUA's interpretation "has the potential to read ["shall be limited"] out of the statute entirely."

Trafficante v. Metropolitan Life Ins.

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United Food Workers v. Brown Group Inc.

May a labor union sue on behalf of its members over alleged violations of the federal Worker Adjustment and Retraining Notification Act?

Yes. In a unanimous decision, authored by Justice David H. Souter, the Court held that the federal Worker Adjustment and Retraining Notification Act grants unions authority to sue for damages on behalf of their members. Therefore, the union had standing to bring such an action. Justice Souter wrote that the court's ruling was based on previous decisions that state that "an organization may sue to redress its members' injuries even without a showing of injury to the association itself."

Wilder v. Virginia Hospital Assoc.

Did the Boren Amendment create a "right" under the definition of 42 U.S.C. 1983, therefore allowing private parties to bring suit challenging the state's finding that its Medicaid reimbursement rates are "reasonable and adequate"? If such a right was created, did Congress intend to prevent private suits to enforce the it?

Yes and no. In a 5-to-4 decision, the Court held that the Boren Amendment clearly established a right to reasonable and adequate reimbursement rates for the hospitals. Justice William J. Brennan, Jr., writing for the majority, stated that a right exists if "the provision in question was intend[ed] to benefit the ... plaintiff." The requirement of reasonable rates was clearly intended to benefit the hospitals, so it amounted to a right under 1983. Without explicit language within the Amendment preventing private suits under 1983, or an alternative remedial scheme that would make such suits unnecessary, it was not reasonable to conclude that Congress had intended to prevent private suits to enforce the right it had created.