What is the impact of a federal administrative order requiring the Department of Justice to review and reinstate an affirmative action program approved by a federal district court?

Appellants allege that if the order is implemented, appellants' past and future compliance efforts will be measured by erroneous legal standards and appellants' ability to retain current contracts and their eligibility for future contracts will be affected by those erroneous standards. The four appellants whose affirmative action programs were disapproved by the district court further allege that approval of their programs will be rescinded and show cause orders will be issued against them, leaving them the choice of preparing new programs or suffering termination of existing contracts and debarment from future contracts. These allegations reflect a "sufficiently direct threat of personal detriment," Planned Parenthood of Missouri v. Danforth, 428 U.S. 52, 62, 96 S.Ct. 2831, 2838, 49 L.Ed.2d 788 (1976), to establish standing. Appellants' interests could not be fully protected in subsequent administrative proceedings since the agency would have no authority to question the validity of the district court's interpretation of the regulations so long as the decree remained in effect. ¹¹