How can I prepare a case to show that an agency’s decision was arbitrary and capricious?
Build your arbitrary-and-capricious case by pinpointing at least one APA §706(2)(A) flaw—ignored key evidence, relied on improper factors, offered no rational explanation, or departed from precedent without reason. Center your argument on citations to the administrative record and applicable statutes/regulations, and preserve procedural objections (notice, comments, bias) early. This article outlines a step-by-step checklist, briefing […]
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