How does the APA define 'arbitrary and capricious' review?

How does the APA define 'arbitrary and capricious' review?

• A. The agency must consider relevant factors and provide a rational explanation; it cannot rely on factors outside the zone of reasonableness or ignore important aspects.
• B. The agency can pick any factors and provide a random justification.
• C. The agency must follow party policy preferences only.
• D. The court should substitute its own judgment about the problem.

Answer: (A)

The main idea is how the APA requires agency decisions to be reasoned and linked to relevant considerations. Under the APA, a decision is not allowed to be arbitrary and capricious. That means the agency must assess the appropriate factors and provide a rational explanation that shows a logical connection between the facts found and the choice made. It cannot rely on factors outside what is reasonable or ignore important aspects of the problem. If the agency fails to consider relevant factors or rests its decision on factors that have no reasonable bearing, the action falls short of the required standard. It also would be improper for the agency to rely on random justification or to act solely on party policy preferences. And while courts review for reasonableness, they do not substitute their own judgment for the agency’s; they defer to the agency so long as the decision is rational within the statutory framework.

The main idea is how the APA requires agency decisions to be reasoned and linked to relevant considerations. Under the APA, a decision is not allowed to be arbitrary and capricious. That means the agency must assess the appropriate factors and provide a rational explanation that shows a logical connection between the facts found and the choice made. It cannot rely on factors outside what is reasonable or ignore important aspects of the problem.

If the agency fails to consider relevant factors or rests its decision on factors that have no reasonable bearing, the action falls short of the required standard. It also would be improper for the agency to rely on random justification or to act solely on party policy preferences. And while courts review for reasonableness, they do not substitute their own judgment for the agency’s; they defer to the agency so long as the decision is rational within the statutory framework.