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Association of Data Processing Service Organizations v. Camp

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Supreme Court of the United States
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 1970United States Supreme Court case that allowed more people to challenge actions of administrative agencies under theAdministrative 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 fromreviewing 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]

HIGHLIGHTS
  • The case: Data processing service companies sued the comptroller of the currency for allowing national banks to provide data processing services if they were incidental to their banking services.
  • The issue: Did the companies have standing to sue the comptroller and were the comptroller's actions subject to judicial review?
  • The outcome: The Supreme Court ruled unanimously that the companies had standing and the comptroller's actions were reviewable under the Administrative Procedure Act.


    • Why it matters: The court developed the zone of interest test, which holds that a plaintiff seekingstanding 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 theEighth Circuit Court of Appeals affirmed that ruling. The case then advanced to the Supreme Court forcertiorari.

    Oral argument

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    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 theUnited States Court of Appeals for the 8th Circuit.[1]

    “Held:

    1. Petitioners have standing to maintain the action.
    (a) Petitioners satisfy the "case" or "controversy" test of Article III of the Constitution, as they allege that the banks' competition causes them economic injury.
    (b) The interest sought to be protected by petitioners is arguably within the one of interests to be protected or regulated by the statute, and petitioners are "aggrieved" persons under § 702 of the Administrative Procedure Act.
    2. Congress did not preclude judicial review of the Comptrollers rulings as to the scope of activities statutorily available to national banks.
    406 F.2d 37, reversed and remanded.[1][4]

    		”

    JusticeWilliam Douglas wrote the majority opinion and was joined by Chief JusticeWarren Burger and JusticesHugo Black,John Harlan II,Potter Stewart,Byron White,Thurgood Marshall, andWilliam Brennan.[5]

    Justice Brennan joined in the majority opinion and noted that his concurring opinion inBarlow v. Collins contained his views.[1]

    Opinions

    Opinion of the court

    Writing for the court, JusticeWilliam Douglas identified two key questions:

    1. Did the companies have standing to sue the Comptroller, either underArticle III or theAdministrative Procedure Act?
    2. 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 theUnited 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, theAdministrative 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]

    InHardin 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] InArnold Tours Inc. v. Camp, which had been decided earlier in 1970, theFirst 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 theArnold ruling and concluded that the companies constituted an aggrieved party and had standing to sue under the Administrative Procedure Act.

    Was judicial review precluded?

    TheAdministrative 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, includingAbbott 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.

    ...
    those whose interests are directly affected by a broad or narrow interpretation of the Acts are easily identifiable. It is clear that petitioners, as competitors of national banks which are engaging in data processing services, are within that class of "aggrieved" persons who, under § 702, are entitled to judicial review of "agency action."[1][4]

    		”

    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 inBarlow 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 asScenic 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 inAbbott 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

    External links

    Footnotes

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    Abbott Laboratories v. Gardner •A.L.A. Schechter Poultry Corp. v. United States •Association of Data Processing Service Organizations v. Camp •Auer v. Robbins •Chevron v. Natural Resources Defense Council •Citizens to Preserve Overton Park v. Volpe •Federal Trade Commission (FTC) v. Standard Oil Company of California •Field v. Clark •Food and Drug Administration v. Brown and Williamson Tobacco Corporation •Humphrey's Executor v. United States •Immigration and Naturalization Service (INS) v. Chadha •J.W. Hampton Jr. & Company v. United States •Lucia v. SEC •Marshall v. Barlow's •Massachusetts v. Environmental Protection Agency •Mistretta v. United States •National Federation of Independent Business (NFIB) v. Sebelius •National Labor Relations Board v. Noel Canning Company •National Labor Relations Board v. Sears, Roebuck & Co. •Panama Refining Co. v. Ryan •Securities and Exchange Commission v. Chenery Corporation •Skidmore v. Swift & Co. •United States v. Lopez •United States v. Western Pacific Railroad Co. •Universal Camera Corporation v. National Labor Relations Board •Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council •Wayman v. Southard •Weyerhaeuser Company v. United States Fish and Wildlife Service •Whitman v. American Trucking Associations •Wickard v. Filburn •Wiener v. United States
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