The Oyez Project: Judicial Power Issues - Statutory Standing

Air Courier Conference v. Postal Workers

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Anza v. Ideal Steel Supply Corporation

Ideal Steel Supply Corporation filed a civil suit against its competitor, National Steel Supply, Inc. in federal court. Ideal alleged that National had failed to charge sales tax for cash purchases, giving it a competitive (but fraudulent) advantage. Under the Racketeer Influenced and Corrupt Organizations Act, "[a]ny person injured in his business or property" by racketeering activity may bring a civil suit. Ideal argued that it had been injured through lost sales because of National's illegal lower prices, and therefore had standing to sue.

The federal district court disagreed, dismissing the suit because Ideal had not had any direct encounters with National or relied on their fraudulent tax records. A Second Circuit Court of Appeals panel reversed the decision, however, finding that a company can sue under RICO when its competitor uses racketeering to gain an advantage.

Bennett v. Spear

When the Fish and Wildlife Service was notified that the operation of the Klamath Irrigation Project might affect two endangered species of fish, it concluded that the proposed long-term operation of the project was likely to jeopardize the species and decided to maintain minimum levels of water in certain reservoirs. The petitioners, irrigation districts receiving project water and operators of ranches in those districts, filed suit against the Service's director, regional directors, and the Secretary, claiming the determination and imposition of minimum water levels violated the Endangered Species Act's requirement that the designated area's economic impact be considered. The District Court dismissed the compliant because it lacked standing; economic interests were not enough to constitute a lawsuit in this matter. The Court of Appeals affirmed.

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

Section 109 of the Federal Credit Union Act provides that that "federal credit union membership shall be limited to groups having a common bond of occupation or association, or to groups within a well-defined neighborhood, community, or rural district." The National Credit Union Administration (NCUA) interprets section 9 to permit federal credit unions to be composed of multiple, unrelated employer groups, each having its own distinct common bond of occupation. Under this interpretation, the NCUA approved a series of charter amendments adding several unrelated employer groups to the membership of AT&T Family Federal Credit Union, which now has approximately 110,000 members nationwide only 35% of whom are employees of AT&T and its affiliates. Subsequently, a number of private actors brought suit under the Administrative Procedure Act, asserting that the NCUA's decision was contrary to law because section 109 unambiguously requires that the same common bond of occupation unite each member of an occupationally defined federal credit union and members of the new groups did not share a common bond of occupation with AT&T Family Federal Credit Union's existing members. Ultimately, the District Court held that the private interests lack standing to challenge NCUA's decision and the Court of Appeals reversed.

Trafficante v. Metropolitan Life Ins.

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United Food Workers v. Brown Group Inc.

The United Food and Commercial Workers Union Local 751 filed suit alleging that Brown Group, Inc. began to lay off workers in connection with the closing of one of its plants, Brown Shoe Company, before giving the union the closing notice required by the federal Worker Adjustment and Retraining Notification Act (the WARN Act). The union sought backpay for each of its affected members. Under modern associational standing doctrine, an organization may sue to redress its members' injuries when: 1) its members would otherwise have standing to sue in their own right; 2) the interests it seeks to protect are germane to the organization's purpose; and 3) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit. The District Court dismissed the compliant. The Court of Appeals affirmed, holding that "[e]ach union member who wishes to recover WARN Act damages from Brown Shoe must participate in the suit so that his or her right to damages can be determined and the quantum of damages can be calculated by the court on the basis of particularized proof." Therefore, the court concluded that the suit was barred because the union failed to meet the third part of the test for asserting associational standing.

Wilder v. Virginia Hospital Assoc.

To qualify for federal funding under the Medicaid Act, states must submit to the Secretary of Health and Human Services a plan that establishes a system by which healthcare providers will be reimbursed. Under the Boren Amendment, the reimbursement rates must be "reasonable and adequate" to meet the costs of efficiently operated facilities.

In 1986, a group of hospitals brought sought against the state of Virginia, arguing that its reimbursement rates (which had been approved in 1982 and again in 1986 by the Secretary) were not "reasonable and adequate." The suit was brought under 42 U.S.C. 1983, which allows individuals or organizations to bring suit for the "deprivation of any rights ... secured by [federal] laws." Virginia argued that the Boren Amendment had not been intended to create a an enforceable right, but simply to provide guidelines for the Secretary to follow, and that the hospitals therefore could not bring suit under 1983. The state also argued that Congress had intended to prevent private parties from bringing suit to enforce the provisions of the Amendment. The District Court disagreed, allowing the suit to proceed. The Fourth Circuit Court of Appeals affirmed.