On July 1, 2024, the U.S. Supreme Court made a significant ruling in the case of Corner Post, Inc. v. Board of Governors of the Federal Reserve System regarding the Administrative Procedure Act (APA). The Court decided that an APA claim only starts when a plaintiff is injured by final agency action. This means that the six-year statute of limitations for APA claims begins when the plaintiff is harmed by the regulation, rather than when the regulation is first issued.
The term “accrues” was a key point of discussion in the ruling, with the Court emphasizing that it has had a clear meaning for over 75 years. According to the Court, a claim accrues when a plaintiff is injured by final agency action, giving them the opportunity to challenge the regulation within the six-year window. Despite concerns raised by the dissent about potential abuse of this ruling, the majority prioritized the clear text of the statute over policy considerations.
The case itself revolved around a Federal Reserve regulation on debit-card transaction fees and involved Corner Post, a North Dakota truck stop that opened for business more than six years after the regulation was issued. The ruling ensures that businesses or individuals affected by regulations, even if they were not initially impacted, have the same opportunity to challenge unlawful agency actions under the APA.
This decision by the Supreme Court expands opportunities for individuals and businesses to challenge federal regulations, ensuring that the six-year clock to bring an APA claim starts when the harm from the agency’s action actually affects the plaintiff. It provides a level playing field for all parties involved, allowing for greater accountability and oversight of agency actions.
Overall, this ruling highlights the importance of clarity and consistency in interpreting legal statutes, emphasizing the need to protect the rights of individuals and businesses when challenging federal regulations. It sets a precedent for future cases involving the APA and underscores the significance of ensuring fair and equitable processes for addressing regulatory issues.
