Department of Education v. Brown

The case arose from a challenge by two student loan borrowers, Myra Brown and Alexander Taylor, who did not qualify for full debt relief under the Biden administration's plan announced in August 2022. They sued the U.S. Department of Education, arguing the program exceeded the HEROES Act and was arbitrary. A federal district court in Texas issued a nationwide injunction, which the Fifth Circuit upheld. The Supreme Court heard the case and on June 30, 2023, ruled unanimously that the plaintiffs lacked Article III standing because they could not show a concrete injury traceable to the plan. The Court therefore vacated the lower court injunction, but the same day in Biden v. Nebraska struck down the loan forgiveness program on the merits, leaving the plan blocked.

The Supreme Court ruled 9-0 that the plaintiffs lacked standing, vacating the Fifth Circuit's nationwide injunction. However, the companion case Biden v. Nebraska separately held that the program exceeded the Department of Education's authority under the HEROES Act, effectively preventing implementation of the debt relief plan.

The central issue was whether the plaintiffs had Article III standing to challenge the student loan debt relief plan, specifically whether they suffered a concrete and particularized injury caused by the program's eligibility exclusions.

The decision, together with Biden v. Nebraska, halted a plan that would have forgiven up to $20,000 in federal student loans for approximately 40 million borrowers. It sparked intense public debate over executive power, the student debt crisis, and the limits of administrative agencies. The ruling was a major setback for the Biden administration and left borrowers without the promised relief, prompting calls for legislative action on student loan reform.