Barlow v. Collins
397 U.S. 159 (1970)
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Rule of Law:
A plaintiff has standing to obtain judicial review of an agency action if they allege an injury in fact and the interest they seek to protect is arguably within the zone of interests to be protected or regulated by the statute in question.
Facts:
- Tenant farmers, including the petitioners, were eligible for payments under the federal upland cotton program established by the Food and Agriculture Act of 1965.
- A statute permitted farmers to assign these payments as security for financing the 'making a crop.'
- Prior to 1966, a regulation from the Secretary of Agriculture explicitly defined 'making a crop' to exclude assignments made to pay for cash rent on a farm.
- In 1966, the Secretary of Agriculture amended the regulation, changing the definition of 'making a crop' to specifically include assignments for the payment of cash rent for land.
- The tenant farmers alleged this new regulation gave their landlords the opportunity to demand the assignment of these government benefits in advance as a mandatory condition for leasing them farmland.
- The farmers claimed this practice forced them to obtain all other farm and living necessities from their landlord at inflated prices and high interest rates, consuming their profits and keeping them in a state of economic dependence.
Procedural Posture:
- Petitioners, a group of cash-rent tenant farmers, filed suit against the Secretary of Agriculture in the U.S. District Court for the Middle District of Alabama, seeking a declaratory judgment and an injunction.
- The District Court dismissed the action, ruling that the petitioners lacked standing to sue.
- The petitioners appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the District Court's dismissal, holding that the petitioners had not alleged an invasion of a legally protected interest and that no statute granted them the right to judicial review.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Do tenant farmers have standing to seek judicial review of an amended regulation by the Secretary of Agriculture that permits them to assign federal farm subsidy payments as security for cash rent, when the farmers allege this change causes them economic injury?
Opinions:
Majority - Mr. Justice Douglas
Yes. Tenant farmers have standing because they have a personal stake in the controversy and fall within the zone of interests the statute was designed to protect. The Court established a two-part test for standing. First, the petitioners satisfied Article III's 'case or controversy' requirement by alleging that the amended regulation caused them injury in fact, creating the necessary personal stake and concrete adverseness. Second, the tenant farmers were clearly within the 'zone of interests' protected by the relevant statutes—the Food and Agriculture Act of 1965 and the Soil Conservation and Domestic Allotment Act—as both laws explicitly direct the Secretary to protect the interests of tenants. Finally, the Court found that judicial review was not precluded, as there was no 'clear and convincing evidence' of congressional intent to restrict access to the courts, and the presumption is in favor of judicial review of administrative actions.
Concurring - Mr. Justice Brennan
Yes. While concurring that the farmers have standing, this opinion dissents from the Court's two-part test, arguing that the sole inquiry for standing should be whether the plaintiff alleges 'injury in fact.' The majority's second step—the 'zone of interests' test—is an unnecessary and confusing inquiry that improperly merges the separate questions of standing, reviewability, and the merits. According to this view, the question of whether a plaintiff is within a statute's zone of interests is relevant to determining whether Congress intended to allow judicial review for that class of plaintiff (reviewability), not whether the plaintiff has the basic constitutional standing to be in court in the first place. The 'injury in fact' alone is sufficient to establish the personal stake required by Article III.
Analysis:
This case, along with its companion case Association of Data Processing Service Organizations, Inc. v. Camp, is significant for establishing the modern two-part test for standing to challenge an administrative agency action. It liberalized the standing doctrine by replacing the older, more restrictive 'legal interest' test, which required a plaintiff to show an invasion of a legally protected right. By adopting the 'injury in fact' and 'zone of interests' framework, the Court broadened access to federal courts for individuals and groups aggrieved by government action, allowing challenges from parties who were arguably intended beneficiaries of a statute, even if the statute did not grant them a specific private right of action.
