National Credit Union Admin. v. First Nat. Bank & Trust Co., 522 U.S. 479, 28 (1998)

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506

NATIONAL CREDIT UNION ADMIN. v. FIRST NAT. BANK & TRUST CO.

O'Connor, J., dissenting

The common bond requirement and the provisions prohibiting credit unions from serving nonmembers combine to limit the customers a credit union can serve, not the services a credit union can offer.

With that understanding, the Court's conclusion that respondents "have" an interest in "limiting the [customer] markets that federal credit unions can serve" means little more than that respondents "have" an interest in enforcing the statute. The common bond requirement limits a credit union's membership, and hence its customer base, to certain groups, 12 U. S. C. § 1759, and in the Court's view, it is enough to establish standing that respondents "have" an interest in limiting the customers a credit union can serve. The Court's additional observation that respondents' interest has been "affected" by the NCUA's interpretation adds little to the analysis; agency interpretation of a statutory restriction will of course affect a party who has an interest in the restriction. Indeed, a party presumably will bring suit to vindicate an interest only if the interest has been affected by the challenged action. The crux of the Court's zone-of-interests inquiry, then, is simply that the plaintiff must "have" an interest in enforcing the pertinent statute.

A party, however, will invariably have an interest in enforcing a statute when he can establish injury in fact caused by an alleged violation of that statute. An example we used in National Wildlife Federation illustrates the point. There, we hypothesized a situation involving "the failure of an agency to comply with a statutory provision requiring 'on the record' hearings." 497 U. S., at 883. That circumstance "would assuredly have an adverse effect upon the company that has the contract to record and transcribe the agency's proceedings," and so the company would establish injury in fact. Ibid. But the company would not satisfy the zone-of-interests test, because "the provision was obviously enacted to protect the interests of the parties to the proceedings and not those of the reporters." Ibid.; see Air Courier,

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