National Credit Union Admin. v. First National Bank & Trust Co. case brief

National Credit Union Admin. v. First National Bank & Trust Co. case brief summary
522 U.S. 479 (1998)

CASE SYNOPSIS

Petitioners, the National Credit Union Association and a federal credit union, appealed an order of the United States Court of Appeals for the District of Columbia Circuit, which reversed two district court decisions and held that respondents, five banks and a bankers' association, had standing under the Administrative Procedure Act, 5 U.S.C.S. § 702, to challenge agency interpretation of the Federal Credit Union Act § 109, 12 U.S.C.S. § 1759.

CASE FACTS
The Federal Credit Union Act § 109 (Act), 12 U.S.C.S. § 1759, limited membership in federal credit unions to groups having a common bond of occupation or association. Petitioner, the National Credit Union Association, interpreted § 109 to permit credit unions to admit unrelated employer groups. Respondents, five banks and a banking association, filed an action under the Administrative Procedure Act, 5 U.S.C.S. § 702, to challenge petitioner's interpretation of the Act as applied to petitioner credit union. The district court dismissed the action twice, and twice the appellate court reversed. On appeal, the court affirmed.

DISCUSSION:

• The court held that respondents had standing and that petitioner agency's construction of the statute was erroneous. 
• Under its prudential standing cases, the court held that respondents were the competitors of petitioner credit union and could challenge petitioner agency's action that relaxed statutory restrictions on their competitor's business. 
• On the merits, the court applied the Chevron rule and noted that Congress had expressly limited membership in credit unions to members of definable groups.
• Petitioner agency's expansive reading of § 109 was impermissible.

OUTCOME

The court affirmed the circuit court's decision. Under its prudential standing cases, the court held that respondent, five banks and a banking association, were competitors of petitioner credit union and had standing to challenge petitioner agency's action that relaxed restrictions on the competitor's activities. Because Congress had expressly limited membership in federal credit unions, petitioner agency's interpretation was impermissible.

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