Nash v. Califano - 613 F.2d 10 (2d Cir. 1980)

Rule:

Standing analysis does not examine the merits of the underlying claim. Rather, the court's inquiry centers solely upon the allegations of the complaint. Taking these allegations to be true, as courts are required to do on an appeal from the dismissal of a complaint for lack of standing, the courts must determine whether the alleged violations are arguably within the zone of interests protected by the statute.

Facts:

Appellant Simon Nash was an Administrative Law Judge (ALJ) for the Social Security Administration's Bureau of Hearings and Appeals (Bureau). Appellee, a new director, was appointed to head the Bureau and he instituted several programs. Appellant alleged that appellees, the director and other officials, and their staff employees interfered with the decisional independence of the ALJs in violation of the Administrative Procedure Act, the Social Security Act, and the due process clause of U.S. Const. amend. V. Appellant filed a formal grievance and was later demoted. The district court dismissed the complaint for lack of standing. Appellant sought review of the decision.

Issue:

Under the circumstances, did appellant have standing to bring the present suit against appellee?

Answer:

Yes.

Conclusion:

The court held that appellant had standing because he had a personal stake and interest in the outcome. The programs instituted by appellee director reached virtually every aspect of the ALJ's daily role. The number of reversals, dispositions, and the manner of trying and deciding each case were recorded and measured against prescribed standards. The court determined that some of these programs impinged upon the decisional independence of the ALJs.