## Facts

- A trade association of independent data-processing firms and member companies sold commercial data-processing services to businesses.
- The Comptroller of the Currency issued a ruling allowing national banks, as incidental to banking services, to provide data-processing services to other banks and to bank customers.
- The plaintiffs alleged that banks’ entry into commercial data processing would cause economic harm through increased competition, including displacement in specific customer relationships.
- Plaintiffs contended the Comptroller’s ruling exceeded statutory limits on the permissible “business of banking” under federal banking laws.
- The federal district court dismissed for lack of standing, and the Eighth Circuit affirmed on the same ground.

## Issues

1. Whether competitors alleging economic harm from agency-authorized bank competition have Article III standing and are “adversely affected or aggrieved” under the Administrative Procedure Act (APA).
2. Whether the relevant banking statutes show congressional intent to preclude judicial review of the Comptroller’s determination regarding permissible national bank activities.

## Decision

- The Supreme Court reversed the dismissal and remanded for further proceedings.
- The Court held the plaintiffs adequately alleged “injury in fact” sufficient to satisfy Article III.
- The Court held the plaintiffs’ interests were “arguably within the zone of interests to be protected or regulated” by the banking statutes they invoked, satisfying the APA’s requirement for review by an “aggrieved” person.
- The Court rejected the “legal interest” test that required a plaintiff to show invasion of a legally protected right as a prerequisite to standing.
- The Court held judicial review was not precluded because the statutory scheme did not clearly bar review of the Comptroller’s ruling.

## Legal Principles

- Article III standing requires a plaintiff to allege “injury in fact,” economic or otherwise; competitive injury can satisfy this requirement.
- Under APA § 702, a plaintiff must show that the interest asserted is arguably within the zone of interests protected or regulated by the statute or constitutional provision relied upon.
- Standing is a threshold inquiry distinct from the merits of whether the agency action violates the statute.
- Agency action is presumptively subject to judicial review absent a clear showing that Congress intended to preclude review.

## Conclusion

Competitors challenging an agency action authorizing banks to offer data-processing services had standing based on economic injury and because their interests were arguably within the relevant statutes’ zone of interests, and the Court allowed the suit to proceed because Congress had not clearly barred judicial review of the Comptroller’s ruling.


Ass’n of Data Processing Serv. Orgs., Inc. v. Camp, 397 U.S. 150 (1970)