Air Courier Conference v. Am. Postal Workers Union

498 U.S. 517, 111 S. Ct. 913 (1991)



To establish standing to sue under the Administrative Procedure Act, plaintiffs must establish that they have suffered a legal wrong because of the challenged agency action, or are adversely affected or aggrieved by agency action within the meaning of a relevant statute.


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.


Did the circuit court of appeals' err in its decision to vacate the district court's grant of summary judgment in favor of the private courier?




The Court reversed the circuit court of appeals' decision vacating the district court's grant of summary judgment in favor of the private courier. The Court held that the unions did not have standing to challenge the regulation. 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.

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