How does the 'record-based' approach affect review of discretionary agency actions?

How does the 'record-based' approach affect review of discretionary agency actions?

• A. Review requires the court to gather new evidence.
• B. Review focuses on the adequacy of the administrative record, including the rationale and the factors considered.
• C. Review only checks compliance with the statute.
• D. Review ignores the record and focuses only on outcomes.

Answer: (B)

In a record-based review, the court centers its analysis on the administrative record—the documents, data, explanations, and factors the agency relied on when making its decision. The key task is to assess whether the agency gave a rational explanation and considered the factors permitted by the statute, and whether the record supports the outcome. The court defers to the agency’s expertise but checks that the decision is not arbitrary or capricious by showing a logical chain from the record to the result. This approach means the court does not typicaly look for new evidence outside what the agency compiled, and it does not evaluate only whether the statute was technically followed without considering the record. It also does not ignore the record in favor of outcomes alone.

In a record-based review, the court centers its analysis on the administrative record—the documents, data, explanations, and factors the agency relied on when making its decision. The key task is to assess whether the agency gave a rational explanation and considered the factors permitted by the statute, and whether the record supports the outcome. The court defers to the agency’s expertise but checks that the decision is not arbitrary or capricious by showing a logical chain from the record to the result.

This approach means the court does not typicaly look for new evidence outside what the agency compiled, and it does not evaluate only whether the statute was technically followed without considering the record. It also does not ignore the record in favor of outcomes alone.