Which scenario demonstrates why an agency error may render a rule invalid under the arbitrary-and-capricious standard?

Which scenario demonstrates why an agency error may render a rule invalid under the arbitrary-and-capricious standard?

• A. The agency failed to weigh conflicting evidence adequately and did not provide a rational explanation.
• B. The agency had extensive public comment.
• C. The agency reached a conclusion with a strong scientific consensus.
• D. The agency followed all procedures but within statutory authority.

Answer: (A)

Under the arbitrary-and-capricious standard, an agency must show a rational connection between the facts found and the choice made, and it must consider and weigh relevant evidence. If the agency fails to weigh conflicting evidence adequately and does not provide a rational explanation for its conclusion, there is no reasonable basis for the rule in the record. That kind of omission signals that the decision was not grounded in the evidence and lacks a logical justification, so it can be struck down as arbitrary and capricious. The other scenarios don’t reveal the same flaw. Extensive public comment reflects consideration of input and transparency in the process rather than a failure to rationally justify the rule. A conclusion backed by strong scientific consensus suggests the agency’s decision has solid evidentiary support. Following procedures and acting within statutory authority shows the action is procedurally proper and within the law, not arbitrary.

Under the arbitrary-and-capricious standard, an agency must show a rational connection between the facts found and the choice made, and it must consider and weigh relevant evidence. If the agency fails to weigh conflicting evidence adequately and does not provide a rational explanation for its conclusion, there is no reasonable basis for the rule in the record. That kind of omission signals that the decision was not grounded in the evidence and lacks a logical justification, so it can be struck down as arbitrary and capricious.

The other scenarios don’t reveal the same flaw. Extensive public comment reflects consideration of input and transparency in the process rather than a failure to rationally justify the rule. A conclusion backed by strong scientific consensus suggests the agency’s decision has solid evidentiary support. Following procedures and acting within statutory authority shows the action is procedurally proper and within the law, not arbitrary.