Federal Trade Commission v. Standard Oil Co. of California
Supreme Court
449 U.S. 232 (1980)
The FTC (defendant, as the agency being sued) filed an administrative complaint in 1973 against Standard Oil Company of California (plaintiff, as the party challenging the complaint), which Socal considered baseless and politically motivated. After exhausting its options for persuading the FTC to withdraw the complaint administratively, Socal sued in federal court, while the FTC proceeding was still pending, to force withdrawal of the complaint, arguing the mere filing and pursuit of a frivolous complaint itself imposed a legal burden requiring it to respond to baseless charges. The district court dismissed the suit as unreviewable, the Ninth Circuit reversed in part, and the Supreme Court granted certiorari given the importance of the reviewability question.
Whether the mere filing of a federal agency's administrative complaint, imposing no burden beyond the need to contest it, constitutes a final agency action subject to judicial review.