Corner Post, Inc. v. Board of Governors
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Corner Post, Inc. v. Board of Governors and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Corner Post, Inc. v. Board of Governors.
The Supreme Court ruled on the timing of when an Administrative Procedure Act (APA) claim accrues, focusing on the requirement that a plaintiff must be injured by final agency action before filing suit. The Court reversed the Eighth Circuit's decision, emphasizing that the statute of limitations does not begin until the plaintiff is injured. This decision impacts how interchange fees are challenged under the APA.
Holding
The single most important “bottom line” of what the Court decided in Corner Post, Inc. v. Board of Governors.
The Court held that an APA claim does not accrue for purposes of the statute of limitations until the plaintiff is injured by final agency action.
Constitutional Concepts
These are the Constitution-related themes that appear in Corner Post, Inc. v. Board of Governors. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Corner Post, Inc. v. Board of Governors
The case involves the interpretation of the Administrative Procedure Act and the limits on agency authority, specifically regarding the timing of when an APA claim accrues.
Syllabus excerpt (verbatim)An APA claim does not accrue for purposes of § 2401(a)'s 6-year statute of limitations until the plaintiff is injured by final agency action.
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Why Judicial Review is relevant to Corner Post, Inc. v. Board of Governors
The case addresses the scope of judicial review under the APA, focusing on when a plaintiff can challenge agency action.
Syllabus excerpt (verbatim)The APA grants Corner Post a cause of action subject to certain conditions, see 5 U. S. C. § 702 and § 704.
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Why Standing is relevant to Corner Post, Inc. v. Board of Governors
The case discusses the requirement for a plaintiff to have suffered an injury in order to bring an APA claim, which is related to standing.
Syllabus excerpt (verbatim)A litigant therefore cannot bring an APA claim unless and until she suffers an injury.
Key Quotes
Short excerpts from the syllabus in Corner Post, Inc. v. Board of Governors that support the summary and concepts above.
An APA claim does not accrue for purposes of § 2401(a)'s 6-year statute of limitations until the plaintiff is injured by final agency action.
A right of action 'accrues' when the plaintiff has a 'complete and present cause of action.'
The Board's arguments to the contrary lack merit.
