In sum, Garrison qualifies for standing because he (and at least some other participants in the Public Service Loan Forgiveness program) actually stand to lose money as a result of the administration’s plan. And that loss is specific to their situation, and not just a result of their general status as federal taxpayers.

This strategy strikes me as sound. It may seem silly that a plaintiff can get standing based on a relatively small financial loss like this one, but taxpayers as a class are not allowed to get it based on the vastly greater fiscal liability Biden’s plan saddles them with, collectively. But that kind of silliness is built into the Supreme Court’s standing precedents, which allow standing based on even a very small individualized material harm (as little as $1 will suffice!), but deny it even for very large fiscal impacts imposed on taxpayers as a class. If you think this is ridiculous, I agree! In my view, the entire doctrine of standing is extremely dubious, and the Supreme Court should abolish it. But that isn’t likely to happen anytime soon.

Under current standing doctrine, it also does not matter if forestalling the relatively small financial loss he stands to suffer is not Garrison and PLF’s true motive for bringing the case. Public interest firms and other litigants routinely bring cases whose primary purpose is to set a more general precedent rather than to mitigate the damages suffered by a specific client. When it comes to standing doctrine, the plaintiffs’ motives for filing a lawsuit are irrelevant, so long as they do in fact have an “injury” of the right type.