Biden v. Nebraska

Summary

The Supreme Court held that Missouri had standing to challenge the federal student-loan forgiveness program because the program would financially harm the Missouri Higher Education Loan Authority, an instrumentality of the State. On the merits, the Court held that the HEROES Act does not authorize the Secretary of Education to cancel approximately $430 billion in student-loan principal, concluding that the program exceeded the Secretary’s authority and lacked clear congressional authorization. The Court reversed and remanded.

Holdings

1. Missouri had standing because MOHELA is an instrumentality of Missouri, and the financial harm to MOHELA caused by the loan-cancellation program was a direct injury to Missouri.
2. The HEROES Act authorizes the Secretary to waive or modify existing statutory or regulatory provisions applicable to Title IV financial-assistance programs, but it does not authorize the Secretary to rewrite the Education Act and create a fundamentally new program canceling approximately $430 billion in student-loan principal.
3. Because the student-loan cancellation plan had extraordinary economic and political significance, the Secretary was required to identify clear congressional authorization; the HEROES Act provided no such authorization.

Questions Presented

1. Whether Missouri had Article III standing based on financial harm to MOHELA, a state-created public corporation.
2. Whether the HEROES Act authorized the Secretary of Education to establish a nationwide program canceling approximately $430 billion in federal student-loan principal.
3. Whether the statutory terms "waive or modify" permit the Secretary to replace existing loan-discharge provisions with a fundamentally new debt-forgiveness regime.
4. Whether the major questions doctrine required clear congressional authorization for the challenged program.

Disposition

reversed_and_remanded