397 U.S. 150 (1970), Supreme Court of the United States
Association of Data Processing Service Organizations v. Camp is a foundational case in federal administrative law that reshaped the doctrine of standing for judicial review of agency action.
Do competitors of national banks have standing under § 10 of the Administrative Procedure Act to challenge the Comptroller of the Currency's ruling permitting national banks to offer data-processing services to nonbank customers, based on alleged economic injury and statutory limits on bank activities?
Under § 10 of the Administrative Procedure Act (5 U.S.C. § 702), a person is entitled to judicial review if they are (1) suffering injury in fact—economic or otherwise—and (2) their interests are arguably within the zone of interests to be protected or regulated by the statute underlying the agency action. The older "legal interest" test is not the proper standard for standing; the question is not whether the plaintiff will prevail on the merits, but whether the plaintiff is an appropriate party to invoke judicial review of the challenged action.
Yes. ADAPSO's members alleged injury in fact from increased competition, and their interests are arguably within the zone of interests protected or regulated by the National Bank Act and the Bank Service Corporation Act. Accordingly, they have standing under the APA to seek review of the Comptroller's ruling.
Data Processing marks the modern starting point for standing in APA cases. It establishes that competitor economic injury is a cognizable injury in fact and introduces the influential zone-of-interests test, significantly broadening who may challenge agency action. For law students, it is essential both doctrinally and methodologically: it clarifies the separation between standing and merits, shows how statutory purposes shape who can sue, and sets the stage for later refinements (e.g., Lujan's traceability/redressability and Lexmark's reclassification of the zone-of-interests inquiry as a matter of statutory cause-of-action scope rather than purely prudential standing). The case is also a staple in understanding judicial review of agency action and the role of competitors in enforcing statutory limits on regulated entities.