## Facts

- Congress granted the United States Postal Service (USPS) a statutory monopoly over the carriage of letters through the Private Express Statutes (PES), primarily to protect USPS revenues from private competition.
- The PES authorize USPS to suspend the monopoly restrictions on a mail route when the public interest requires.
- USPS issued a regulation permitting “international remailing,” allowing private couriers to carry letters for deposit with foreign postal services for delivery abroad.
- Postal employee unions alleged that the regulation would divert mail volume from USPS and reduce postal workers’ employment opportunities.
- The unions sued under the Administrative Procedure Act (APA), contending that USPS lacked adequate support for finding the suspension was in the public interest.

## Issues

1. Whether the unions had standing under the APA to challenge USPS’s regulation suspending PES restrictions for international remailing.
2. Whether the unions’ alleged employment-related injury fell within the “zone of interests” protected or regulated by the PES.

## Decision

- The Supreme Court reversed the D.C. Circuit and held that the unions lacked standing under the APA.
- The Court concluded that the unions’ asserted injury to employment opportunities was not arguably within the zone of interests protected or regulated by the PES.
- Because standing was absent, the Court did not reach whether the PES suspension was “in the public interest.”
- The Court declined to decide whether USPS is exempt from APA judicial review under 39 U.S.C. § 410(a) because the issue was not properly presented.

## Legal Principles

- In APA suits, a plaintiff must satisfy Article III requirements and also show that the interest asserted is arguably within the “zone of interests” to be protected or regulated by the statute allegedly violated.
- The zone-of-interests inquiry, while not demanding, excludes plaintiffs whose interests are only marginally related to or inconsistent with the statute’s purposes.
- The PES were enacted to protect USPS revenues; incidental effects on postal employment do not make employment interests protected interests under the PES.
- Courts may resolve cases on standing grounds without addressing broader questions about the scope of APA review when those questions are not properly before the Court.

## Conclusion

The Court held that postal employee unions could not use the APA to challenge USPS’s authorization of international remailing because the PES protect USPS revenue, not postal employment, placing the unions’ asserted injury outside the statutes’ zone of interests and foreclosing judicial review on the merits.


Air Courier Conference of Am. v. Am. Postal Workers Union, AFL-CIO, 498 U.S. 517 (1991)