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See also Administrative law (appellate review: reviewability: standing) A person suing under the Administrative Procedures Act  must satisfy not only Article III's standing requirements, but an additional test: The interest he asserts must be “arguably within the zone of interests to be protected or regulated by the statute” that he says was violated. Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 153, 90 S. Ct. 827, 25 L. Ed. 2d 184 (1970). 


This prudential standing test “is not meant to be especially demanding.” Clarke v. Securities Industry Assn., 479 U.S. 388, 399, 107 S. Ct. 750, 93 L. Ed. 2d 757 (1987). Courts apply the test in keeping with Congress's “evident intent” when enacting the APA “to make agency action presumptively reviewable.” Ibid. Courts do not require any “indication of congressional purpose to benefit the would-be plaintiff.” Id., at 399-400, 107 S. Ct. 750, 93 L. Ed. 2d 757. And courts have always conspicuously included the word “arguably” in the test to indicate that the benefit of any doubt goes to the plaintiff. The test forecloses suit only when a plaintiff's “interests are so marginally related to or ...

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