National Credit Union Administration v. First National Bank & Trust Co.

Summary

The Court held that competing banks had standing under the Administrative Procedure Act to challenge the NCUA's interpretation of the Federal Credit Union Act because their interest in limiting credit unions' markets was arguably within the zone of interests protected by § 109. It further held that § 109 unambiguously required the same common bond of occupation to unite all members of an occupationally defined federal credit union, making the NCUA's authorization of unrelated employer groups impermissible at Chevron's first step. Justice Thomas wrote for the Court; Justice Scalia joined except as to footnote 6. Justice O'Connor dissented, joined by Justices Stevens, Souter, and Breyer, arguing that the banks' competitive interests were not protected by the common-bond provision and that the Court's analysis effectively collapsed the zone-of-interests requirement into injury in fact. She would have vacated and remanded with instructions to dismiss.