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FEDERAL ELECTION COMMISSION v. AKINS, 524 U.S. 11 (1998)

SUBJECT:

Standing - Zone of interest

FACTS:

A group of voters sought review of the Federal Election Commission's (FEC) decision dismissing their administrative complaint, which alleged that an organization was a "political committee" under the Federal Election Campaign Act (FECA), and thus, should have been subject to registration and reporting requirements.

Procedure:

The United States District Court for the District of Columbia, June L. Green, J., granted summary judgment for the FEC, and the voters appealed. After remanding for clarification, 1992 WL 183209, the Court of Appeals, District of Columbia Circuit, en banc, 101 F.3d 731, vacating an earlier panel decision, 66 F.3d 348, reversed.

ISSUE:

Whether an organization was a "political committee" and should have been subject to registration and reporting requirements. Whether plaintiffs had standing to bring this case.

RULE:

Prudential standing is satisfied when the injury asserted by a plaintiff arguably falls within the zone of interests to be protected or regulated by the statute in question.

HOLDING:

The Supreme Court, Justice Breyer, held that the voters had standing to bring the suit. The case was brought by people whom the statute was designed to protect.

Vacated and remanded.

RATIONALE:

A group of voters satisfied prudential standing requirements in an action in which the voters alleged that an organization was a "political committee" under the Federal Election Campaign Act (FECA), and thus, subject to registration and reporting requirements; the injury of which the voters complained, their failure to obtain relevant information, was injury of a kind that FECA sought to address.

POLICY/NOTES:

Justice Scalia dissented. He saw this as a generalized grievance which does not give standing.