Elizabeth Federal Savings and Loan Association v. Charles R. Howell

Summary

The Court held that the competing savings and loan institutions have standing to seek judicial review of the Commissioner’s approval of Colonial’s branch office, that the limited hearing provided was insufficient because the record was not exclusive, and that the Commissioner acted within his statutory authority under subsection B. Accordingly, the case was remanded to the Commissioner for completion of the record and further findings. The Court emphasized that standing may arise from a slight private interest harmonized with a substantial public interest. Justice Burling dissented, arguing that the Commissioner lacked authority to approve a branch at a location distant from the former office and that the application should be dismissed.