Department of Education v. Brown

Brown's exclusion and Taylor's reduced relief created concrete injuries, but neither plaintiff could demonstrate that their harm resulted from the procedural defect they challenged the lack of notice-and-comment rulemaking rather than from the program's substantive eligibility requirements set by Congress and the agency. Brown was excluded because her loans were commercially held, a limitation rooted in the statute itself; Taylor's lesser relief reflected the scope of benefits Congress designed the program to provide. Without showing that proper notice-and-comment procedures would have altered the eligibility requirements or benefit structure, neither plaintiff could establish that a favorable ruling on the procedural claim would redress their actual injury. Thus, the procedural right to notice-and-comment rulemaking could not confer standing when the plaintiffs' injuries flowed directly from substantive policy choices, not from the manner in which the rule was adopted.