How does the 'record rule' govern judicial review of agency actions?

How does the 'record rule' govern judicial review of agency actions?

• A. Courts typically review the administrative record to assess the agency’s reasoning and factual findings rather than considering outside evidence.
• B. Courts may consider new evidence presented by parties to supplement the record.
• C. Courts rely on executive summaries and press releases.
• D. Courts ignore the agency’s factual findings and focus on policy outcomes.

Answer: (A)

Judicial review of agency actions centers on the administrative record—the materials the agency actually relied on when deciding. The record rule keeps review focused on that record, so courts assess the agency’s reasoning and factual findings using only what was before the agency at the time of decision. This ensures that the decision is evaluated against the same evidentiary basis the agency used, avoiding new evidence or post hoc arguments shaping the outcome. There are limited exceptions where extra-record materials can be considered, but the default approach is to rely on the administrative record and not permit broad introduction of outside evidence.

Judicial review of agency actions centers on the administrative record—the materials the agency actually relied on when deciding. The record rule keeps review focused on that record, so courts assess the agency’s reasoning and factual findings using only what was before the agency at the time of decision. This ensures that the decision is evaluated against the same evidentiary basis the agency used, avoiding new evidence or post hoc arguments shaping the outcome.

There are limited exceptions where extra-record materials can be considered, but the default approach is to rely on the administrative record and not permit broad introduction of outside evidence.