Supreme Court of the United States
Air Courier Conference of America v. American Postal Workers Union, Afl-Cio
February 26, 1991498 U.S. 517
Summary
Chief Justice Rehnquist's opinion of the Court held that postal employees fall outside the zone of interests protected by the Private Express Statutes and therefore cannot challenge the Postal Service's suspension of those statutes for international remailing. The statutes protect postal revenues to ensure nationwide service, not postal employment, and their inclusion in the Postal Reorganization Act does not connect them sufficiently to that Act's labor protections. The Court also concluded that an exemption from APA review is a waivable, nonjurisdictional defense and declined to decide whether the Postal Service was exempt. It reversed without reaching the regulation's validity. Justice Stevens, joined by Justices Marshall and Blackmun, concurred in the judgment, reasoning instead that 39 U.S.C. § 410(a) excludes APA review and makes the zone-of-interests question unnecessary.
Holding
- Whether postal employees are within the zone of interests protected by the Private Express Statutes.. Postal employees are outside the protected zone of interests and lack standing to challenge the suspension permitting international remailing.
- Whether the Postal Reorganization Act's labor protections can supply the protected interest necessary to challenge the suspension.. The labor-management provisions do not bring postal employment within the zone of interests protected by the Private Express Statutes merely because both appear in the same comprehensive enactment.
- Whether the asserted statutory exemption from APA review must be resolved as a jurisdictional question.. A defense based on exemption from the APA is waivable and nonjurisdictional; the Court declined to decide whether § 410(a) exempts the Postal Service from APA review.
Docket 89-1416
Cited authorities
- Rule 12.4
- 18 U.S.C. §§ 1693-1699
- 39 U.S.C. §§ 601-606
- 18 U.S.C. §§ 1693-1699
- 39 U.S.C. §§ 601-606
- CA10
- 18 U.S.C. §§ 1693-1699
- 39 U.S.C. §§ 601-606
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