Who has standing to file an Article 78 petition?

• A. Any resident may file an Article 78 petition.
• B. Only corporations may file.
• C. A person with no interest but who disagrees may file.
• D. A person with a direct, substantial, and recognizable interest harmed by the agency's determination.

Answer: (D)

Standing to file an Article 78 petition rests on injury in fact. The person or entity bringing the petition must have a direct, personal, and legally recognizable interest that has been harmed by the agency’s determination. Article 78 is about judicial review of agency actions, so the petitioner must be aggrieved in a concrete way, not merely disagree with the result or have a general interest in the matter.

This is why the best answer describes someone who has a direct, substantial, and recognizable interest harmed by the agency’s determination. A blanket claim based on residence is too broad, because not every resident is personally harmed. A blanket rule that only corporations can file is incorrect, and someone with no stake or injury but mere disagreement does not have standing.