## Facts

- Seventeen members of the U.S. House Committee on Oversight and Government Reform submitted a written request to the General Services Administration (GSA) for information under 5 U.S.C. § 2954.
- Section 2954 requires an executive agency, upon request of the committee or “any seven members” of it, to submit requested information relating to matters within the committee’s jurisdiction.
- The members sought documents about GSA’s administration of a long-term lease of the Old Post Office Building in Washington, D.C., operated as the Trump International Hotel, including GSA’s legal analysis of compliance with constitutional and statutory requirements.
- GSA refused to provide the requested documents.
- The members sued the GSA Administrator in federal district court seeking an order compelling production.
- The district court dismissed the complaint for lack of Article III standing, reasoning the asserted injury was institutional to the House and resembled a generalized legislative grievance.
- The members appealed to the D.C. Circuit.

## Issues

1. Whether individual members of Congress have Article III standing to sue an executive agency to enforce an information request made under 5 U.S.C. § 2954.
2. Whether the alleged injury from an agency’s refusal is a concrete, particularized informational injury to the requesting members or a nonjusticiable institutional injury to Congress under principles reflected in Raines v. Byrd.
3. Whether the injury is fairly traceable to the agency’s refusal and likely to be redressed by an order compelling production.

## Decision

- The D.C. Circuit reversed the dismissal and remanded.
- The court held the members had Article III standing because the agency’s refusal to provide information allegedly required by § 2954 constituted a concrete and particularized informational injury.
- The court concluded the injury was personal to the requesting members as holders of a statutory entitlement, not an undifferentiated institutional injury shared by Congress as a whole.
- The court found traceability satisfied because the injury flowed directly from GSA’s refusal to comply with the request.
- The court found redressability satisfied because an order compelling production would provide the requested information.
- A dissent would have treated the dispute as an interbranch political conflict not suitable for judicial resolution and warned against expanding legislative standing.

## Legal Principles

- The denial of information that a plaintiff is statutorily entitled to obtain can constitute a concrete, particularized injury-in-fact for Article III standing.
- When a statute confers a right to information on a defined subset of legislators, those legislators may assert a personal informational injury from an executive agency’s refusal to provide it.
- Legislative-standing limits applicable to generalized claims of diminished legislative power do not necessarily bar suits seeking enforcement of a specific statutory entitlement to information.
- For informational-injury claims, causation and redressability are satisfied where the injury is the agency’s refusal to disclose and the requested relief is an order compelling disclosure.

## Conclusion

The D.C. Circuit held that members of a House oversight committee had standing to sue to enforce a § 2954 information request because the executive agency’s refusal to provide information allegedly mandated by statute inflicted a personal, concrete informational injury that was directly caused by the refusal and could be remedied by a disclosure order.


Maloney v. Murphy, 984 F.3d 50 (D.C. Cir. 2020)