Cases by Issue - Statutory Standing

Anza v. Ideal Steel Supply Corporation

Mon, 05 Jan 2009 17:45:18 +0000

Case Basics

Docket No.

04-433

Petitioner

Joseph Anza, et al.

Petitioner Type

Petitioner

Respondent

Ideal Steel Supply Corp.

Respondent Type

Respondent

Heard By

Roberts Court (2006-2009)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Monday, November 28, 2005

Argued

Monday, March 27, 2006

Decided

Monday, June 5, 2006

Advocates

Kevin P. Roddy (argued the cause for Respondent)

David C. Frederick (argued the cause for Petitioners)

Facts of the Case

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.

Question

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?

Conclusion

Decision: 9 votes for Anza, 0 vote(s) against
Legal provision: Racketeer Influenced and Corrupt Organizations

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.

National Credit Union Administration v. First National Bank

Mon, 05 Jan 2009 16:15:01 +0000

Case Basics

Docket No.

96-843

Petitioner

National Credit Union Administration

Respondent

First National Bank

Consolidation

No. 96-847

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

522 U.S. 479 (1998)

Argued

Monday, October 6, 1997

Decided

Wednesday, February 25, 1998

Advocates

Seth P. Waxman (on behalf of the Federal Petitioner)

John G. Roberts, Jr. (on behalf of the Private Petitioners)

Michael S. Helfer (on behalf of the Respondents)

Facts of the Case

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.

Question

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?

Conclusion

Decision: 5 votes for First National Bank, 4 vote(s) against
Legal provision: 12 U.S.C. 1759

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."

Bennett v. Spear

Mon, 05 Jan 2009 16:15:46 +0000

Case Basics

Docket No.

95-813

Petitioner

Bennett

Petitioner Type

Petitioner

Respondent

Spear

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

520 U.S. 154 (1997)

Argued

Wednesday, November 13, 1996

Decided

Wednesday, March 19, 1997

Advocates

Edwin S. Kneedler (Argued the cause for the respondents)

Gregory K. Wilkerson (Argued the cause for the petitioners)

Gregory K. Wilkinson (on behalf of the Petitioners)

Facts of the Case

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.

Question

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

Conclusion

Decision: 9 votes for Bennett, 0 vote(s) against
Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

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.

United Food Workers v. Brown Group Inc.

Mon, 05 Jan 2009 16:24:45 +0000

Case Basics

Docket No.

95-340

Petitioner

United Food Workers

Petitioner Type

Petitioner

Respondent

Brown Group Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 544 (1996)

Argued

Tuesday, February 20, 1996

Decided

Monday, May 13, 1996

Advocates

Lan Jenkins (On behalf of the United States, as amicus curiae, supporting the petitioner)

Alan Jenkins (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Laurence E. Gold (Argued the cause for the petitioner)

Thomas C. Walsh (Argued the cause for the respondent)

Facts of the Case

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.

Question

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

Conclusion

Decision: 9 votes for United Food Workers, 0 vote(s) against
Legal provision: 29 U.S.C. 2101

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."

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

Mon, 05 Jan 2009 16:15:17 +0000

Case Basics

Docket No.

93-1783

Petitioner

Director, Office Of Workers' Compensation Programs, Department Of Labor

Petitioner Type

Petitioner

Respondent

Newport News Shipbuilding & Dry Dock Co. et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

514 U.S. 122 (1995)

Argued

Monday, January 9, 1995

Decided

Tuesday, March 21, 1995

Advocates

Beth S. Brinkmann (on behalf of the Petitioner)

Lawrence P. Postol (on behalf of the Respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Newport News Shipbuilding & Dry Dock Co., 0 vote(s) against
Legal provision: Longshoremen and Harbor Workers' Compensation

None

Holmes v. Securities Investor Protection Corporation

Mon, 05 Jan 2009 16:24:04 +0000

Case Basics

Docket No.

90-727

Petitioner

Holmes

Petitioner Type

Petitioner

Respondent

Securities Investor Protection Corporation et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

503 U.S. 258 (1992)

Argued

Wednesday, November 13, 1991

Decided

Tuesday, March 24, 1992

Advocates

G. Robert Blakey (on behalf of the Respondents)

Jack I. Samet (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Holmes, 0 vote(s) against
Legal provision: Racketeer Influenced and Corrupt Organizations

None

Gollust v. Mendell

Mon, 05 Jan 2009 16:16:14 +0000

Case Basics

Docket No.

90-659

Petitioner

Gollust

Petitioner Type

Petitioner

Respondent

Mendell

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1990-1991)

Opinion

501 U.S. 115 (1991)

Argued

Monday, April 15, 1991

Decided

Monday, June 10, 1991

Advocates

Edwin B. Mishkin (on behalf of the Petitioners)

Irving Malchman (on behalf of the Respondents)

James R. Doty (on behalf of SEC, as amicus curiae, in support of Respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Mendell, 0 vote(s) against
Legal provision: Securities Act of 1933, the Securities and Exchange Act of 1934, or the Williams Act

None

Air Courier Conference v. Postal Workers

Mon, 05 Jan 2009 16:16:12 +0000

Case Basics

Docket No.

89-1416

Petitioner

Air Courier Conference

Petitioner Type

Petitioner

Respondent

Postal Workers

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1990-1991)

Opinion

498 U.S. 517 (1991)

Argued

Wednesday, November 28, 1990

Decided

Tuesday, February 26, 1991

Advocates

Keith E. Secular (on behalf of the Private Respondents)

L. Peter Farkas (on behalf of the Petitioner)

Paul J. Larkin, Jr. (on behalf of the Federal Respondent supporting the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Air Courier Conference, 0 vote(s) against
Legal provision: 5 U.S.C. 702

None

Wilder v. Virginia Hospital Assoc.

Mon, 05 Jan 2009 17:30:01 +0000

Case Basics

Docket No.

88-2043

Petitioner

Wilder

Respondent

Virginia Hospital Assoc.

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

496 U.S. 498 (1990)

Argued

Tuesday, January 9, 1990

Decided

Thursday, June 14, 1990

Advocates

R. Claire Guthrie (Argued the cause for petitioners)

John G. Roberts, Jr. (Argued the cause for the United States as amicus curiae urging reversal)

Walter E. Dellinger, III (Argued the cause for the Respondent)

Facts of the Case

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.

Question

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?

Conclusion

Decision: 5 votes for Virginia Hospital Assoc., 4 vote(s) against
Legal provision: Medicaid--provisions of the Social Security Act

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.

Jackson Transit Authority v. Transit Union

Mon, 05 Jan 2009 17:30:49 +0000

Case Basics

Docket No.

81-411

Petitioner

Jackson Transit Authority

Petitioner Type

Petitioner

Respondent

Transit Union

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

457 U.S. 15 (1982)

Argued

Wednesday, April 21, 1982

Decided

Monday, June 7, 1982

Advocates

Joseph S. Kaufman (on behalf of the Petitioners)

Linda R. Hirshman (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Jackson Transit Authority, 0 vote(s) against
Legal provision: 49 U.S.C. 1609

None

Havens Realty Corp. v. Coleman

Mon, 05 Jan 2009 17:30:28 +0000

Case Basics

Docket No.

80-988

Petitioner

Havens Realty Corp.

Petitioner Type

Petitioner

Respondent

Coleman

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

455 U.S. 363 (1982)

Argued

Tuesday, December 1, 1981

Decided

Wednesday, February 24, 1982

Advocates

Vanessa Ruiz (on behalf of the Respondents)

Everette G. Allen, Jr. (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Havens Realty Corp., 0 vote(s) against
Legal provision: Fair Housing

None

Gladstone, Realtors v. Village Of Bellwood

Mon, 05 Jan 2009 17:12:00 +0000

Case Basics

Docket No.

77-1493

Petitioner

Gladstone, Realtors

Petitioner Type

Petitioner

Respondent

Village Of Bellwood

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

441 U.S. 91 (1979)

Argued

Wednesday, November 29, 1978

Decided

Tuesday, April 17, 1979

Advocates

Lawrence G. Wallace (argued the cause for the United States as amicus curiae urging affirmance)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Village Of Bellwood, 2 vote(s) against
Legal provision: Fair Housing

None

United States v. Scrap

Mon, 05 Jan 2009 17:19:55 +0000

Case Basics

Docket No.

72-535

Appellee

Scrap

Petitioner Type

Appellee

Appellant

United States

Respondent Type

Appellant

Consolidation

No. 72-562

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

412 U.S. 669 (1973)

Argued

Wednesday, February 28, 1973

Decided

Monday, June 18, 1973

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United States, 2 vote(s) against
Legal provision: National Environmental Policy

None

Trafficante v. Metropolitan Life Ins.

Mon, 05 Jan 2009 17:19:22 +0000

Case Basics

Docket No.

71-708

Petitioner

Trafficante

Petitioner Type

Petitioner

Respondent

Metropolitan Life Ins.

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

409 U.S. 205 (1972)

Argued

Tuesday, November 7, 1972

Decided

Thursday, December 7, 1972

Advocates

Lawrence G. Wallace (argued the cause for the United States as amicus curiae urging reversal)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Trafficante, 0 vote(s) against
Legal provision: Fair Housing

None

Caplin v. Marine Midland Grace Trust Co.

Mon, 05 Jan 2009 16:31:02 +0000

Case Basics

Docket No.

70-220

Petitioner

Caplin

Petitioner Type

Petitioner

Respondent

Marine Midland Grace Trust Co.

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

406 U.S. 416 (1972)

Argued

Tuesday, March 28, 1972

Decided

Monday, May 22, 1972

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Marine Midland Grace Trust Co., 4 vote(s) against
Legal provision: Bankruptcy Code, Bankruptcy Act or Rules, or Bankruptcy Reform Act of 1978

None

Gutknecht v. United States

Mon, 05 Jan 2009 17:39:19 +0000

Case Basics

Docket No.

Petitioner

Gutknecht

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Burger Court (1969-1970)

Decided By

Burger Court (1969-1970)

Opinion

396 U.S. 295 (1970)

Argued

Thursday, November 20, 1969

Decided

Monday, January 19, 1970

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Gutknecht, 0 vote(s) against
Legal provision: Selective Service, Military Selective Service, or Universal Military Service and Training Acts

None

Sullivan v. Little Hunting Park

Mon, 05 Jan 2009 17:39:02 +0000

Case Basics

Docket No.

Petitioner

Sullivan

Petitioner Type

Petitioner

Respondent

Little Hunting Park

Respondent Type

Respondent

Heard By

Burger Court (1969-1970)

Decided By

Burger Court (1969-1970)

Opinion

396 U.S. 229 (1969)

Argued

Monday, October 13, 1969

Decided

Monday, December 15, 1969

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Sullivan, 3 vote(s) against
Legal provision: Fair Housing

None

Hardin v. Kentucky Utilities Co.

Mon, 05 Jan 2009 17:41:28 +0000

Case Basics

Docket No.

Petitioner

Hardin

Respondent

Kentucky Utilities Co.

Consolidation

No. 50

No. 51

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

390 U.S. 1 (1968)

Argued

Wednesday, December 13, 1967

Decided

Tuesday, January 16, 1968

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Hardin, 1 vote(s) against
Legal provision: 16 U.S.C. 831

None

Ftc v. Dean Foods Co.

Mon, 05 Jan 2009 17:44:02 +0000

Case Basics

Docket No.

970

Petitioner

Ftc

Petitioner Type

Petitioner

Respondent

Dean Foods Co.

Respondent Type

Respondent

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

384 U.S. 597 (1966)

Argued

Monday, March 28, 1966

Decided

Monday, June 13, 1966

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Ftc, 4 vote(s) against
Legal provision: 28 U.S.C. 1651

None

American Trucking Assns. v. U.S.

Mon, 05 Jan 2009 16:30:37 +0000

Case Basics

Docket No.

Appellee

U.S.

Petitioner Type

Appellee

Appellant

American Trucking Assns.

Respondent Type

Appellant

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

364 U.S. 1 (1960)

Argued

Thursday, May 19, 1960

Decided

Monday, June 27, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for American Trucking Assns., 0 vote(s) against
Legal provision: Interstate Commerce, as amended

None

U.S. v. Storer Broadcasting Co.

Mon, 05 Jan 2009 16:25:23 +0000

Case Basics

Docket No.

Petitioner

U.S.

Respondent

Storer Broadcasting Co.

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

351 U.S. 192 (1956)

Argued

February 28-29, 1956

Decided

Monday, May 21, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for U.S., 2 vote(s) against
Legal provision: Communication Act of 1934

None