The concept of agency discretion and its limits under the arbitrary and capricious standard of review is a cornerstone of administrative law in the United States. This standard, derived from the Administrative Procedure Act (APA), serves as a crucial check on the power of federal agencies, ensuring that their actions are reasonable, justified, and within the bounds of their statutory authority. Understanding the nuances of agency discretion and how it is constrained by arbitrary and capricious review is essential for legal practitioners, policymakers, and anyone involved in the regulatory process.
At its core, agency discretion refers to the latitude given to administrative agencies in interpreting and implementing statutes, making policy decisions, and carrying out their mandated functions. This discretion is rooted in the recognition that agencies often possess specialized expertise and are better positioned than courts or legislators to make certain technical or policy determinations. However, this discretion is not unlimited, and the arbitrary and capricious standard serves as a key mechanism for courts to ensure that agencies do not abuse their power or make decisions that lack a rational basis.
The arbitrary and capricious standard, as codified in the APA, requires courts to set aside agency actions that are found to be “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” This standard has been further refined through numerous court decisions, most notably in the Supreme Court’s landmark ruling in Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co. In this case, the Court articulated what has come to be known as “hard look” review, emphasizing that agencies must provide a reasoned explanation for their decisions, consider relevant factors, and address significant alternatives.
One of the primary ways in which the arbitrary and capricious standard limits agency discretion is by requiring agencies to demonstrate a rational connection between the facts found and the choice made. This means that agencies cannot simply assert their conclusions without providing a logical explanation for how they arrived at their decision. Courts will scrutinize the agency’s reasoning process to ensure that it has considered all relevant factors and has not relied on factors that Congress did not intend it to consider.
For example, in a case involving environmental regulations, an agency might be required to explain how it weighed scientific evidence, economic impacts, and statutory mandates in reaching its decision. If the agency fails to adequately address a significant aspect of the problem or offers an explanation that runs counter to the evidence before it, a court may find the action arbitrary and capricious.
Another important aspect of the arbitrary and capricious standard is its requirement that agencies consider reasonable alternatives to their chosen course of action. While agencies are not required to analyze every possible alternative, they must give serious consideration to important alternatives that are brought to their attention during the decision-making process. This requirement serves to ensure that agencies do not simply default to a predetermined outcome without considering other viable options.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to changes in policy. While agencies are allowed to change their policies over time, they must provide a reasoned explanation for doing so. This principle was emphasized in the Supreme Court’s decision in FCC v. Fox Television Stations, Inc., where the Court held that while agencies are not always required to provide a more detailed justification for a policy change than what would suffice for a new policy created on a blank slate, they must at least display awareness that they are changing position and provide good reasons for the new policy.
This requirement serves as an important check on political influence in agency decision-making. It ensures that changes in agency policy are not merely the result of shifting political winds but are grounded in reasoned analysis and consideration of relevant factors. For instance, if an agency decides to reverse a long-standing environmental protection policy, it would need to explain why the new approach is justified, addressing any reliance interests that may have developed under the old policy and providing a rational basis for the change.
The arbitrary and capricious standard also limits agency discretion by requiring agencies to respond to significant comments received during the rulemaking process. This requirement ensures that agencies engage meaningfully with stakeholder input and do not simply ignore relevant information or perspectives that are brought to their attention. If an agency fails to address a significant comment that, if true, would require a change in the proposed rule, a court may find the resulting action arbitrary and capricious.
In the context of scientific and technical decisions, the arbitrary and capricious standard requires agencies to provide a reasoned explanation for their choices, even when dealing with complex or uncertain issues. While courts generally defer to agency expertise in these areas, they will still scrutinize the agency’s reasoning process to ensure that it has considered relevant scientific evidence and has not ignored important aspects of the problem.
For example, in a case involving the regulation of greenhouse gas emissions, an agency would need to demonstrate that it has considered the best available scientific evidence on climate change, addressed any significant uncertainties, and provided a rational explanation for its regulatory approach. If the agency were to ignore significant scientific studies or fail to explain why it chose one methodology over another, a court might find its action arbitrary and capricious.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to statutory interpretation. While the Chevron doctrine provides agencies with significant deference in interpreting ambiguous statutes, the arbitrary and capricious standard ensures that agencies do not interpret statutes in ways that are unreasonable or contrary to congressional intent. This interplay between Chevron deference and arbitrary and capricious review adds another layer of complexity to the limits on agency discretion.
For instance, if an agency interprets a statute in a way that seems to contradict its plain language or legislative history, a court might find this interpretation arbitrary and capricious, even if the statute is ambiguous. This serves as an important check on agencies’ ability to expand their own power through creative statutory interpretation.
The arbitrary and capricious standard also limits agency discretion by requiring agencies to consider the reliance interests that have developed around existing policies. This principle was emphasized in the Supreme Court’s decision in Department of Homeland Security v. Regents of the University of California, which dealt with the rescission of the Deferred Action for Childhood Arrivals (DACA) program. The Court held that the agency’s failure to consider the reliance interests of DACA recipients rendered its decision arbitrary and capricious.
This aspect of the standard is particularly important in cases where agency actions have significant impacts on individuals or businesses that have made long-term decisions based on existing policies. For example, if an agency were to suddenly change regulations affecting a particular industry, it would need to consider and address the potential disruption to businesses that have invested heavily in compliance with the existing regulations.
Another way in which the arbitrary and capricious standard limits agency discretion is by requiring agencies to provide contemporaneous explanations for their actions. Courts have held that agencies cannot rely on post hoc rationalizations to justify their decisions. This means that the reasons an agency gives for its action at the time of the decision are crucial, and agencies cannot later invent new justifications if their original reasoning is found to be flawed.
This principle serves to ensure transparency and accountability in agency decision-making. It prevents agencies from making decisions based on improper motives and then searching for legitimate justifications after the fact. For example, if an agency were to make a decision based on political pressure but later attempt to justify it with technical or policy reasons, a court would likely find this action arbitrary and capricious if the true motivations were revealed.
The arbitrary and capricious standard also plays a role in limiting agency discretion when it comes to the use of guidance documents and other informal agency pronouncements. While agencies have significant latitude in issuing guidance to interpret their own regulations or statutes, courts have held that agencies cannot use guidance documents to create new legal obligations without going through proper rulemaking procedures.
This principle was emphasized in cases like Appalachian Power Co. v. EPA, where the court held that an agency cannot use guidance documents to expand the scope of its regulations beyond what was reasonably contemplated in the original rulemaking. This limitation on agency discretion helps to ensure that significant policy changes are subject to public notice and comment, rather than being implemented through less formal means.
The arbitrary and capricious standard also serves to limit agency discretion in the context of enforcement decisions. While agencies generally have broad discretion in deciding how to allocate their enforcement resources, courts have held that this discretion is not unlimited. For example, in Heckler v. Chaney, the Supreme Court recognized that there may be cases where an agency’s refusal to take enforcement action is so extreme as to amount to an abdication of its statutory responsibilities, which could be found arbitrary and capricious.
This principle is particularly important in areas like environmental law or consumer protection, where agency enforcement decisions can have significant impacts on public health and safety. While courts are generally reluctant to second-guess agency enforcement priorities, the arbitrary and capricious standard provides a mechanism for challenging enforcement decisions that seem to contradict the agency’s statutory mandate or established policies.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the consideration of costs and benefits in regulatory decision-making. In Michigan v. EPA, the Supreme Court held that the Environmental Protection Agency’s failure to consider costs at the initial stage of deciding whether to regulate power plant emissions was arbitrary and capricious. This decision emphasized that, unless Congress has explicitly directed otherwise, agencies must treat cost as a relevant factor in their decision-making processes.
This aspect of the standard is particularly important in the context of major regulatory actions that can have significant economic impacts. It requires agencies to engage in a reasoned analysis of the costs and benefits of their proposed actions, rather than focusing solely on the benefits or ignoring economic considerations altogether. For example, if an agency were to propose a new workplace safety regulation, it would need to consider not only the potential health benefits but also the costs of implementation and any potential economic disruptions.
The arbitrary and capricious standard also serves to limit agency discretion by requiring agencies to explain any departures from past practices or precedents. While agencies are allowed to change their policies over time, courts have held that they must provide a reasoned explanation for such changes. This principle was articulated in cases like FCC v. Fox Television Stations, Inc., where the Court emphasized that agencies must display awareness that they are changing position and provide good reasons for the new policy.
This requirement is particularly important in ensuring consistency and predictability in agency decision-making. It prevents agencies from making arbitrary shifts in policy without adequate justification, which could otherwise undermine public trust and create uncertainty for regulated entities. For instance, if an agency were to suddenly reverse a long-standing interpretation of a regulation, it would need to explain why the new interpretation is more appropriate, addressing any reliance interests that may have developed under the old interpretation.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the treatment of scientific uncertainty. In areas where scientific knowledge is evolving or where there are competing scientific theories, agencies must demonstrate that they have considered the range of scientific opinion and have provided a reasoned explanation for their choices.
This principle was emphasized in cases like Chlorine Chemistry Council v. EPA, where the court held that an agency’s failure to adequately explain its treatment of scientific uncertainty rendered its decision arbitrary and capricious. This aspect of the standard is particularly important in areas like environmental regulation or public health, where agencies often must make decisions based on complex and sometimes conflicting scientific evidence.
For example, if an agency were setting air quality standards, it would need to explain how it weighed different scientific studies, addressed uncertainties in the data, and arrived at its final decision. If the agency were to ignore significant scientific evidence or fail to explain why it chose one scientific model over another, a court might find its action arbitrary and capricious.
The arbitrary and capricious standard also serves to limit agency discretion by requiring agencies to consider the practical consequences of their actions. Courts have held that agencies must take into account the real-world impacts of their decisions, rather than relying solely on abstract principles or theoretical models.
This principle was articulated in cases like Michigan v. EPA, where the Court emphasized the importance of considering regulatory costs, and in Judulang v. Holder, where the Court found an immigration policy arbitrary and capricious because it bore no relation to the practical realities of the immigration system.
This aspect of the standard is particularly important in ensuring that agency decisions are grounded in reality and do not lead to unintended or absurd consequences. For instance, if an agency were to propose a new regulation without considering its feasibility or the potential for unintended negative consequences, a court might find this action arbitrary and capricious.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the use of data and statistics. Courts have held that agencies must use reliable data and sound statistical methods in their decision-making processes. If an agency relies on flawed data or employs questionable statistical techniques, a court may find its action arbitrary and capricious.
This principle is particularly important in the era of big data and advanced analytics, where agencies increasingly rely on complex data analysis to inform their decisions. For example, if an agency were to base a significant policy decision on a statistical analysis that experts widely criticized as flawed or biased, a court might find this reliance arbitrary and capricious.
In conclusion, the arbitrary and capricious standard serves as a crucial check on agency discretion, ensuring that administrative actions are reasonable, justified, and within the bounds of statutory authority. By requiring agencies to provide reasoned explanations for their decisions, consider relevant factors, address significant alternatives, and respond to important comments, this standard helps to promote transparency, accountability, and rational decision-making in the administrative state.
As the complexity of regulatory issues continues to grow and agencies face new challenges in areas like environmental protection, public health, and emerging technologies, the role of the arbitrary and capricious standard in constraining agency discretion remains more important than ever. Legal practitioners, policymakers, and stakeholders must continue to engage with these principles to ensure that agency actions serve the public interest while respecting the limits of administrative power.
Sources:
- https://www.law.cornell.edu/uscode/text/5/706
- https://supreme.justia.com/cases/federal/us/463/29/
- https://supreme.justia.com/cases/federal/us/556/502/
- https://supreme.justia.com/cases/federal/us/576/591/
Citations:
[1] https://attorneys.media/arbitrary-capricious-standard-legal-situations/
[2] https://attorneys.media/arbitrary-and-capricious/
[3] https://blog.theodorewatson.com/arbitrary-and-capricious-standard-for-challenging-an-agency-action/
[4] https://clarkcountybar.org/what-does-arbitrary-or-capricious-mean/
[5] https://archive.epic.org/open_gov/Administrative-Procedure-Act.html
[6] https://ballotpedia.org/Arbitrary-or-capricious_test
[7] https://blog.counselstack.com/arbitrary-and-capricious-standard-definition-application-and-review-2/
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Agency discretion limits under arbitrary and capricious review
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The concept of agency discretion and its limits under the arbitrary and capricious standard of review is a cornerstone of administrative law in the United States. This standard, derived from the Administrative Procedure Act (APA), serves as a crucial check on the power of federal agencies, ensuring that their actions are reasonable, justified, and within the bounds of their statutory authority. Understanding the nuances of agency discretion and how it is constrained by arbitrary and capricious review is essential for legal practitioners, policymakers, and anyone involved in the regulatory process.
At its core, agency discretion refers to the latitude given to administrative agencies in interpreting and implementing statutes, making policy decisions, and carrying out their mandated functions. This discretion is rooted in the recognition that agencies often possess specialized expertise and are better positioned than courts or legislators to make certain technical or policy determinations. However, this discretion is not unlimited, and the arbitrary and capricious standard serves as a key mechanism for courts to ensure that agencies do not abuse their power or make decisions that lack a rational basis.
The arbitrary and capricious standard, as codified in the APA, requires courts to set aside agency actions that are found to be “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” This standard has been further refined through numerous court decisions, most notably in the Supreme Court’s landmark ruling in Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co. In this case, the Court articulated what has come to be known as “hard look” review, emphasizing that agencies must provide a reasoned explanation for their decisions, consider relevant factors, and address significant alternatives.
One of the primary ways in which the arbitrary and capricious standard limits agency discretion is by requiring agencies to demonstrate a rational connection between the facts found and the choice made. This means that agencies cannot simply assert their conclusions without providing a logical explanation for how they arrived at their decision. Courts will scrutinize the agency’s reasoning process to ensure that it has considered all relevant factors and has not relied on factors that Congress did not intend it to consider.
For example, in a case involving environmental regulations, an agency might be required to explain how it weighed scientific evidence, economic impacts, and statutory mandates in reaching its decision. If the agency fails to adequately address a significant aspect of the problem or offers an explanation that runs counter to the evidence before it, a court may find the action arbitrary and capricious.
Another important aspect of the arbitrary and capricious standard is its requirement that agencies consider reasonable alternatives to their chosen course of action. While agencies are not required to analyze every possible alternative, they must give serious consideration to important alternatives that are brought to their attention during the decision-making process. This requirement serves to ensure that agencies do not simply default to a predetermined outcome without considering other viable options.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to changes in policy. While agencies are allowed to change their policies over time, they must provide a reasoned explanation for doing so. This principle was emphasized in the Supreme Court’s decision in FCC v. Fox Television Stations, Inc., where the Court held that while agencies are not always required to provide a more detailed justification for a policy change than what would suffice for a new policy created on a blank slate, they must at least display awareness that they are changing position and provide good reasons for the new policy.
This requirement serves as an important check on political influence in agency decision-making. It ensures that changes in agency policy are not merely the result of shifting political winds but are grounded in reasoned analysis and consideration of relevant factors. For instance, if an agency decides to reverse a long-standing environmental protection policy, it would need to explain why the new approach is justified, addressing any reliance interests that may have developed under the old policy and providing a rational basis for the change.
The arbitrary and capricious standard also limits agency discretion by requiring agencies to respond to significant comments received during the rulemaking process. This requirement ensures that agencies engage meaningfully with stakeholder input and do not simply ignore relevant information or perspectives that are brought to their attention. If an agency fails to address a significant comment that, if true, would require a change in the proposed rule, a court may find the resulting action arbitrary and capricious.
In the context of scientific and technical decisions, the arbitrary and capricious standard requires agencies to provide a reasoned explanation for their choices, even when dealing with complex or uncertain issues. While courts generally defer to agency expertise in these areas, they will still scrutinize the agency’s reasoning process to ensure that it has considered relevant scientific evidence and has not ignored important aspects of the problem.
For example, in a case involving the regulation of greenhouse gas emissions, an agency would need to demonstrate that it has considered the best available scientific evidence on climate change, addressed any significant uncertainties, and provided a rational explanation for its regulatory approach. If the agency were to ignore significant scientific studies or fail to explain why it chose one methodology over another, a court might find its action arbitrary and capricious.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to statutory interpretation. While the Chevron doctrine provides agencies with significant deference in interpreting ambiguous statutes, the arbitrary and capricious standard ensures that agencies do not interpret statutes in ways that are unreasonable or contrary to congressional intent. This interplay between Chevron deference and arbitrary and capricious review adds another layer of complexity to the limits on agency discretion.
For instance, if an agency interprets a statute in a way that seems to contradict its plain language or legislative history, a court might find this interpretation arbitrary and capricious, even if the statute is ambiguous. This serves as an important check on agencies’ ability to expand their own power through creative statutory interpretation.
The arbitrary and capricious standard also limits agency discretion by requiring agencies to consider the reliance interests that have developed around existing policies. This principle was emphasized in the Supreme Court’s decision in Department of Homeland Security v. Regents of the University of California, which dealt with the rescission of the Deferred Action for Childhood Arrivals (DACA) program. The Court held that the agency’s failure to consider the reliance interests of DACA recipients rendered its decision arbitrary and capricious.
This aspect of the standard is particularly important in cases where agency actions have significant impacts on individuals or businesses that have made long-term decisions based on existing policies. For example, if an agency were to suddenly change regulations affecting a particular industry, it would need to consider and address the potential disruption to businesses that have invested heavily in compliance with the existing regulations.
Another way in which the arbitrary and capricious standard limits agency discretion is by requiring agencies to provide contemporaneous explanations for their actions. Courts have held that agencies cannot rely on post hoc rationalizations to justify their decisions. This means that the reasons an agency gives for its action at the time of the decision are crucial, and agencies cannot later invent new justifications if their original reasoning is found to be flawed.
This principle serves to ensure transparency and accountability in agency decision-making. It prevents agencies from making decisions based on improper motives and then searching for legitimate justifications after the fact. For example, if an agency were to make a decision based on political pressure but later attempt to justify it with technical or policy reasons, a court would likely find this action arbitrary and capricious if the true motivations were revealed.
The arbitrary and capricious standard also plays a role in limiting agency discretion when it comes to the use of guidance documents and other informal agency pronouncements. While agencies have significant latitude in issuing guidance to interpret their own regulations or statutes, courts have held that agencies cannot use guidance documents to create new legal obligations without going through proper rulemaking procedures.
This principle was emphasized in cases like Appalachian Power Co. v. EPA, where the court held that an agency cannot use guidance documents to expand the scope of its regulations beyond what was reasonably contemplated in the original rulemaking. This limitation on agency discretion helps to ensure that significant policy changes are subject to public notice and comment, rather than being implemented through less formal means.
The arbitrary and capricious standard also serves to limit agency discretion in the context of enforcement decisions. While agencies generally have broad discretion in deciding how to allocate their enforcement resources, courts have held that this discretion is not unlimited. For example, in Heckler v. Chaney, the Supreme Court recognized that there may be cases where an agency’s refusal to take enforcement action is so extreme as to amount to an abdication of its statutory responsibilities, which could be found arbitrary and capricious.
This principle is particularly important in areas like environmental law or consumer protection, where agency enforcement decisions can have significant impacts on public health and safety. While courts are generally reluctant to second-guess agency enforcement priorities, the arbitrary and capricious standard provides a mechanism for challenging enforcement decisions that seem to contradict the agency’s statutory mandate or established policies.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the consideration of costs and benefits in regulatory decision-making. In Michigan v. EPA, the Supreme Court held that the Environmental Protection Agency’s failure to consider costs at the initial stage of deciding whether to regulate power plant emissions was arbitrary and capricious. This decision emphasized that, unless Congress has explicitly directed otherwise, agencies must treat cost as a relevant factor in their decision-making processes.
This aspect of the standard is particularly important in the context of major regulatory actions that can have significant economic impacts. It requires agencies to engage in a reasoned analysis of the costs and benefits of their proposed actions, rather than focusing solely on the benefits or ignoring economic considerations altogether. For example, if an agency were to propose a new workplace safety regulation, it would need to consider not only the potential health benefits but also the costs of implementation and any potential economic disruptions.
The arbitrary and capricious standard also serves to limit agency discretion by requiring agencies to explain any departures from past practices or precedents. While agencies are allowed to change their policies over time, courts have held that they must provide a reasoned explanation for such changes. This principle was articulated in cases like FCC v. Fox Television Stations, Inc., where the Court emphasized that agencies must display awareness that they are changing position and provide good reasons for the new policy.
This requirement is particularly important in ensuring consistency and predictability in agency decision-making. It prevents agencies from making arbitrary shifts in policy without adequate justification, which could otherwise undermine public trust and create uncertainty for regulated entities. For instance, if an agency were to suddenly reverse a long-standing interpretation of a regulation, it would need to explain why the new interpretation is more appropriate, addressing any reliance interests that may have developed under the old interpretation.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the treatment of scientific uncertainty. In areas where scientific knowledge is evolving or where there are competing scientific theories, agencies must demonstrate that they have considered the range of scientific opinion and have provided a reasoned explanation for their choices.
This principle was emphasized in cases like Chlorine Chemistry Council v. EPA, where the court held that an agency’s failure to adequately explain its treatment of scientific uncertainty rendered its decision arbitrary and capricious. This aspect of the standard is particularly important in areas like environmental regulation or public health, where agencies often must make decisions based on complex and sometimes conflicting scientific evidence.
For example, if an agency were setting air quality standards, it would need to explain how it weighed different scientific studies, addressed uncertainties in the data, and arrived at its final decision. If the agency were to ignore significant scientific evidence or fail to explain why it chose one scientific model over another, a court might find its action arbitrary and capricious.
The arbitrary and capricious standard also serves to limit agency discretion by requiring agencies to consider the practical consequences of their actions. Courts have held that agencies must take into account the real-world impacts of their decisions, rather than relying solely on abstract principles or theoretical models.
This principle was articulated in cases like Michigan v. EPA, where the Court emphasized the importance of considering regulatory costs, and in Judulang v. Holder, where the Court found an immigration policy arbitrary and capricious because it bore no relation to the practical realities of the immigration system.
This aspect of the standard is particularly important in ensuring that agency decisions are grounded in reality and do not lead to unintended or absurd consequences. For instance, if an agency were to propose a new regulation without considering its feasibility or the potential for unintended negative consequences, a court might find this action arbitrary and capricious.
The arbitrary and capricious standard also plays a crucial role in limiting agency discretion when it comes to the use of data and statistics. Courts have held that agencies must use reliable data and sound statistical methods in their decision-making processes. If an agency relies on flawed data or employs questionable statistical techniques, a court may find its action arbitrary and capricious.
This principle is particularly important in the era of big data and advanced analytics, where agencies increasingly rely on complex data analysis to inform their decisions. For example, if an agency were to base a significant policy decision on a statistical analysis that experts widely criticized as flawed or biased, a court might find this reliance arbitrary and capricious.
In conclusion, the arbitrary and capricious standard serves as a crucial check on agency discretion, ensuring that administrative actions are reasonable, justified, and within the bounds of statutory authority. By requiring agencies to provide reasoned explanations for their decisions, consider relevant factors, address significant alternatives, and respond to important comments, this standard helps to promote transparency, accountability, and rational decision-making in the administrative state.
As the complexity of regulatory issues continues to grow and agencies face new challenges in areas like environmental protection, public health, and emerging technologies, the role of the arbitrary and capricious standard in constraining agency discretion remains more important than ever. Legal practitioners, policymakers, and stakeholders must continue to engage with these principles to ensure that agency actions serve the public interest while respecting the limits of administrative power.
Sources:
Citations:
[1] https://attorneys.media/arbitrary-capricious-standard-legal-situations/
[2] https://attorneys.media/arbitrary-and-capricious/
[3] https://blog.theodorewatson.com/arbitrary-and-capricious-standard-for-challenging-an-agency-action/
[4] https://clarkcountybar.org/what-does-arbitrary-or-capricious-mean/
[5] https://archive.epic.org/open_gov/Administrative-Procedure-Act.html
[6] https://ballotpedia.org/Arbitrary-or-capricious_test
[7] https://blog.counselstack.com/arbitrary-and-capricious-standard-definition-application-and-review-2/
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