Seattle Bldg. & Constr. Trades Council v. Apprenticeship & Training Council
In Seattle Bldg. & Constr. Trades Council v. Apprenticeship & Training Council, 129 Wn.2d 787, 920 P.2d 581 (1996), labor organizations with trade apprenticeship programs existing at the time that a public agency approved the standards for, and registration of, a competing apprenticeship program, sought judicial review of the question of whether this approval required a formal adjudicatory hearing.
The Court found that these organizations had standing based upon the likely diminishment of employment opportunities as a result of the agency's decision for apprentices of "existing programs, including their own." Trades Council, 129 Wn.2d at 796.
Thus, the "injury in fact" and "zone of interest" prongs of the APA standing test were satisfied. See RCW 34.05.530.
The Court noted "where an agency refuses to provide a procedure required by statute or the Constitution, the United States Supreme Court 'routinely grants standing to a party' despite the fact that 'any injury to substantive rights attributable to failure to provide a procedure is both indirect and speculative.'"