Association of Data Processing Service Organizations v. Camp
 | |
| Association of Data Processing Service Organizations, Inc. v. Camp | |
| Reference: 397 U.S. 150 (1970) | |
| Term: 1969 | |
| Important Dates | |
| Argued: November 18, 1969 Decided: March 3, 1970 | |
| Outcome | |
| United States Court of Appeals for the 8th Circuit reversed and remanded | |
| Majority | |
| Warren Burger • Hugo Black • William Douglas • John Harlan II • Potter Stewart • Byron White • Thurgood Marshall | |
| Concurring | |
| William Brennan | |
| Dissenting | |
| None | |
Association of Data Processing Service Organizations, Inc. v. Camp is a 1970 United States Supreme Court case that allowed more people to challenge actions of administrative agencies under the Administrative Procedure Act (APA). In this case, the court held that data processors could sue the comptroller of the currency and that Congress had not blocked courts from reviewing the comptroller's actions. The case was part of a judicial trend during the 1960s aimed at allowing more parties to have standing to challenge agency actions in court.[1][2]
Why it matters:
The court developed the zone of interest test, which holds that a plaintiff seeking standing must allege an “injury in fact” and demonstrate that their interest is "arguably within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question.”[3]
Background
The Comptroller's Manual for National Banks, published October 15, 1966, stated the following:
| “ | Incidental to its banking services, a national bank may make available its data processing equipment or perform data processing services on such equipment for other banks and bank customers.[1][4] | ” |
The data processing companies sued the Comptroller over this provision. The District Court dismissed the complaint and the Eighth Circuit Court of Appeals affirmed that ruling. The case then advanced to the Supreme Court for certiorari.
Oral argument
| Administrative State |
|---|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
Oral argument was held on November 18, 1969. The case was decided on March 3, 1970.[1]
Decision
The Supreme Court ruled unanimously that the Association of Data Processing Service Organizations had standing to sue and that Congress had not precluded judicial review of the Comptroller's actions, reversing and remanding the decision of the United States Court of Appeals for the 8th Circuit.[1]
| “ | Held:
1. Petitioners have standing to maintain the action.
|
” |
Justice William Douglas wrote the majority opinion and was joined by Chief Justice Warren Burger and Justices Hugo Black, John Harlan II, Potter Stewart, Byron White, Thurgood Marshall, and William Brennan.[5]
Justice Brennan joined in the majority opinion and noted that his concurring opinion in Barlow v. Collins contained his views.[1]
Opinions
Opinion of the court
Writing for the court, Justice William Douglas identified two key questions:
- Did the companies have standing to sue the Comptroller, either under Article III or the Administrative Procedure Act?
- Was judicial review of the Comptroller's actions precluded by the relevant public or case law?
Standing under Article III
Article III, Section 2 of the United States Constitution states that the judicial power of the federal courts applies only to cases and controversies.
| “ | ...the question of standing in the federal courts is to be considered in the framework of Article III, which restricts judicial power to "cases" and "controversies."[1][4] | ” |
To meet this qualification, the companies had to prove that the Comptroller's ruling caused them direct economic injury, which Douglas argued it had.
| “ | There can be no doubt but that petitioners have satisfied this test. The petitioners not only allege that competition by national banks...might entail some future loss of profits for the petitioners, they also allege that [the] respondent...was performing or preparing to perform such services for two customers for whom petitioner Data Systems, Inc., had previously agreed or negotiated to perform such services.[1][4] | ” |
He concluded that the companies had standing to sue under Article III.
Standing under the Administrative Procedure Act
As Justice Douglas noted, the Administrative Procedure Act gave standing to challenge an agency action to any person or party "aggrieved by agency action within the meaning of a relevant statute."[1] He interpreted this further to mean that any complainant with an interest that fell "within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question."[1]
In Hardin v. Kentucky Utilities Co., the Supreme Court had set the precedent that "no explicit statutory provision was necessary to confer standing, since the private utility bringing suit was within the class of persons that the statutory provision was designed to protect."[1] In Arnold Tours Inc. v. Camp, which had been decided earlier in 1970, the First Circuit Court of Appeals had ruled that Section 4 of the Bank Service Corporation Act gave a data processing company standing to contest the legality of a bank providing data processing services to other banks and customers.[1] Section 4 of the act reads as follows:
| “ | No bank service corporation may engage in any activity other than the performance of bank services for banks.[1][4] | ” |
Douglas affirmed the logic of the Arnold ruling and concluded that the companies constituted an aggrieved party and had standing to sue under the Administrative Procedure Act.
Was judicial review precluded?
The Administrative Procedure Act allowed for judicial review of agency actions "except to the extent that -- (1) statutes preclude judicial review; or (2) agency action is committed to agency discretion by law."[1] Douglas drew on past congressional reports and several cases, including Abbott Laboratories v. Gardner, to argue that any statute precluding judicial review must do so clearly and unambiguously, and that failure to explicitly provide for judicial review did not automatically preclude it.[1] He found no clear indication of preclusion in either the Bank Service Corporation Act or the National Bank Act.
| “ | We find no evidence that Congress, in either the Bank Service Corporation Act or the National Bank Act, sought to preclude judicial review of administrative rulings by the Comptroller as to the legitimate scope of activities available to national banks under those statutes.
... |
” |
With nothing precluding judicial review of the Comptroller's actions, the companies had standing to sue and the case was remanded to the Appeals Court for a hearing on its merits.
Concurring opinions
Justice Brennan joined in the majority opinion and noted that his concurring opinion in Barlow v. Collins contained his views.[1]
Dissenting opinions
There were no dissenting opinions.
Impact
In his discussion of standing under the Administrative Procedure Act, Justice Douglas noted the recent tendency toward expanding the definition of aggrieved persons under the act.
| “ | Where statutes are concerned, the trend is toward enlargement of the class of people who may protest administrative action. The whole drive for enlarging the category of aggrieved "persons" is symptomatic of that trend.[1][4] | ” |
Rulings such as Scenic Hudson Preservation Conference v. FPC had played a key part in this expansion. That decision gave standing to parties who derived "aesthetic, conservational, and recreational" value from the subject of an action, which opened the door to an increase in agency-related litigation in the subsequent years. The precedent set in Abbott Laboratories v. Gardner, that the absence of an explicit judicial review provision did not preclude judicial review, compounded that trend, as did the ruling in this case.
See also
- Abbott Laboratories v. Gardner
- Administrative Procedure Act
- Nondelegation doctrine
- Separation of powers
- Rulemaking
- Administrative law
- Supreme Court of the United States
- History of the Supreme Court
External links
- Full Text of the Case via Justia
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 1.13 1.14 1.15 1.16 1.17 Justia, Data Processing Svc. Orgs. v. Camp, accessed November 29, 2017
- ↑ Justia, "Substantial Interest: Standing," accessed March 1, 2024
- ↑ Law Library—American Law and Legal Information, "Administrative Law and Procedure—Judicial Review Of Agency Actions," accessed October 22, 2020
- ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Oyez, "Association of Data Processing Service Organizations, Inc. v. Camp," accessed November 29, 2017
| |||||||||||