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.
Corner Post, Inc. challenged the Federal Reserve Board's Regulation II, which sets interchange fees for debit card transactions, arguing it allowed higher fees than permitted by statute. The case focused on whether the six-year statute of limitations under 28 U.S.C. § 2401(a) for Administrative Procedure Act claims begins when the agency action is final or when the plaintiff is injured by the action. The Supreme Court reversed the Eighth Circuit's decision, holding that the statute of limitations begins when the plaintiff is injured by the final agency action.
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 Administrative Procedure Act claim does not accrue for purposes of the six-year 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 Due Process is relevant to Corner Post, Inc. v. Board of Governors
The case involves the application of the Administrative Procedure Act, which implicates procedural due process rights in ensuring that agency actions do not harm individuals without proper legal recourse.
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 Separation of Powers is relevant to Corner Post, Inc. v. Board of Governors
The case involves judicial review of agency action, which is a function of the separation of powers between the executive branch (Federal Reserve Board) and the judiciary.
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.
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,' which is when she has the right to 'file suit and obtain relief.'
The Board's policy concerns are overstated because regulated parties may always challenge a regulation as exceeding the agency's statutory authority in enforcement proceedings against them.