Air Courier Conference of America v. American Postal Workers
Union, AFL-CIO case brief summary
498 U.S. 517 (1991)
CASE FACTS
Two unions comprised of United States Postal Service (USPS) employees filed suit under the APA challenging an international remailing regulation promulgated by the USPS that allowed a private courier to employ overnight delivery of letters to foreign countries as an exception to the Private Express Statutes (PES), 18 U.S.C.S. §§ 1693-1699 and 39 U.S.C.S. §§ 601-606. The district court granted summary judgment to the private courier; however, the circuit court of appeals vacated that decision on the grounds that the unions satisfied the zone-of-interests requirement for APA review and that the USPS's regulation was arbitrary and capricious. The private courier appealed and the Court held that the unions did not have standing to challenge the regulation.
DISCUSSION
OUTCOME
The Court reversed the circuit court of appeals' decision vacating the district court's grant of summary judgment in favor of the private courier.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
498 U.S. 517 (1991)
CASE SYNOPSIS
Petitioner, a private courier, appealed
a decision of the United States Court of Appeals for the District of
Columbia Circuit, which vacated a decision of a district court that
granted summary judgment to the private courier in respondent unions'
suit challenging an international remailing regulation pursuant to
the judicial review provisions of the Administrative Procedure Act
(APA), specifically 5 U.S.C.S. § 702.CASE FACTS
Two unions comprised of United States Postal Service (USPS) employees filed suit under the APA challenging an international remailing regulation promulgated by the USPS that allowed a private courier to employ overnight delivery of letters to foreign countries as an exception to the Private Express Statutes (PES), 18 U.S.C.S. §§ 1693-1699 and 39 U.S.C.S. §§ 601-606. The district court granted summary judgment to the private courier; however, the circuit court of appeals vacated that decision on the grounds that the unions satisfied the zone-of-interests requirement for APA review and that the USPS's regulation was arbitrary and capricious. The private courier appealed and the Court held that the unions did not have standing to challenge the regulation.
DISCUSSION
- The Court found the postal monopoly codified in the PES existed to ensure that postal services would be provided to the citizenry at large and not to secure employment for postal workers.
- The Court found no connection between the PES and the protections of labor-management provisions of the Postal Reorganization Act, 39 U.S.C.S. § 101 et seq., sufficient to create a zone-of-interest in the unions.
OUTCOME
The Court reversed the circuit court of appeals' decision vacating the district court's grant of summary judgment in favor of the private courier.
Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)
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