The D.C. Circuit issued four opinions last week, and none squarely fall into the admin law category. There was a criminal case, a case about defamation claims under D.C. law, and a case about multiemployer pension fund liabilities.

The fourth case was not about agency action, but it did address standing principles that come up in agency cases. In Angelo v. District of Columbia, No. 24-7127, the D.C. Circuit held that plaintiffs had standing to challenge the ban on carrying firearms on the Metro, reversing the district court’s dismissal of their claims for lack of standing. Plaintiffs based their standing on the allegation that to “avoid criminal prosecution, they have each been forced to take alternative and more expensive modes of transportation within the District.” The district court held that was insufficient because plaintiffs had not alleged an especially high probability that the gun ban would be enforced against them. The D.C. Circuit rejected that reasoning, distinguishing between standing based solely on the threat of imminent prosecution and standing based on an “economic loss caused by compliance with an allegedly unconstitutional law.” Because plaintiffs had alleged that sort of loss (additional transportation costs due to inability to take the Metro while exercising their Second Amendment rights), they had standing to pursue their claims.