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 reversed the Eighth Circuit's decision, holding that an APA claim does not accrue until the plaintiff is injured by final agency action. The case involved Corner Post, Inc.'s challenge to the Federal Reserve Board's Regulation II, which sets interchange fees. The Court determined that the statute of limitations begins when the plaintiff suffers an injury, not when the agency action becomes final.
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 revolves around the interpretation of the Administrative Procedure Act and the limits on agency authority regarding interchange fees.
Syllabus excerpt (verbatim)The APA grants Corner Post a cause of action subject to certain conditions, see 5 U. S. C. § 702 and § 704, and 28 U. S. C. § 2401(a) delineates the time period in which Corner Post may assert its claim.
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Why Judicial Review is relevant to Corner Post, Inc. v. Board of Governors
The Court's decision involves the power of courts to review and invalidate agency action under the APA.
Syllabus excerpt (verbatim)The APA grants Corner Post a cause of action subject to certain conditions... and § 704 provides that judicial review is available in most cases only for 'final agency action.'
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Why Standing is relevant to Corner Post, Inc. v. Board of Governors
The case discusses when a plaintiff has standing to bring an APA claim, focusing on when the injury occurs.
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 Court 'will not infer such an odd result in the absence of any such indication in the text of the limitations period.'