Friday, November 1, 2013

Association of Data Processing Service Organizations, Inc. v. Camp case brief

Association of Data Processing Service Organizations, Inc. v. Camp case brief summary
397 U.S. 150 (1970)

Petitioner data processing service providers sought certiorari review of a judgment from the United States Court of Appeals for the Eighth Circuit, which affirmed the dismissal of their complaint challenging a decision from respondent Comptroller of the Currency that authorized banks to sell data processing services.

The data processing providers sought judicial review of the Comptroller's ruling that allowed national banks to offer competing data processing services. The providers argued that, inter alia, that it violated the Bank Service Corporation Act of 1962, 12 U.S.C.S. § 1864, which restricted bank service corporations from engaging in any activity other than performing bank services. The appellate court affirmed the dismissal of their complaint, concluding that the providers lacked standing because they had not alleged the invasion of a legal right arising out of a public charter, contract, statute, or public interest in which they were significantly involved.

  • On certiorari review, the United States Supreme Court held that the providers satisfied the necessary standing requirements by showing an economic injury in fact attributable to the Comptroller's ruling and because they sought to protect an interest that was arguably within the zone of interest to be protected by the Bank Service Corporation Act. 
  • Thus, the providers were entitled to judicial review of the Comptroller's action pursuant to the Administrative Procedure Act, 5 U.S.C.S. § 702, as persons aggrieved by the agency action.


The Court reversed the judgments of the lower courts and remanded the case for a hearing on the merits.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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