Department of Education v. Brown

Summary

The Supreme Court held that Myra Brown and Alexander Taylor lacked Article III standing to challenge the Department of Education’s student-loan forgiveness plan on procedural grounds. The Court concluded that any injury from not receiving loan relief under a potential Higher Education Act program was not fairly traceable to the Department’s adoption of the plan under the HEROES Act. The Court vacated the judgment and remanded with instructions to dismiss.

Holdings

1. A plaintiff asserting deprivation of a procedural right must still show a concrete interest affected by the deprivation; a procedural right in the abstract is insufficient to establish Article III standing.
2. Respondents' alleged injury—the absence of loan relief under the HEA—was not fairly traceable to the Department's decision to provide loan relief under the HEROES Act.
3. Because respondents lacked Article III standing, the Court lacked jurisdiction to reach their procedural challenge and was required to vacate the District Court's judgment and remand with instructions to dismiss.

Questions Presented

1. Whether respondents had Article III standing to challenge the Department's failure to conduct negotiated rulemaking and notice and comment in promulgating the HEROES Act loan-forgiveness plan.
2. Whether respondents' alleged denial of potential loan relief under the Higher Education Act was fairly traceable to the Department's adoption of the HEROES Act plan.
3. Whether the District Court's judgment vacating the plan should be vacated and the case remanded with instructions to dismiss.

Disposition

vacated