Standard of review for adjudication
🔷 Standard of Review for Administrative Adjudication
🔹 What is Administrative Adjudication?
Administrative adjudication is the process by which administrative agencies resolve disputes involving rights or obligations.
Unlike rulemaking (which creates general rules), adjudication applies rules to specific parties.
Adjudications can be formal (similar to court hearings, under APA § 554) or informal (less procedural rigor).
🔹 Why is Standard of Review Important?
Courts must balance agency expertise and finality with protection of individual rights.
The standard of review determines how much deference a court gives to an agency’s findings of fact, conclusions of law, or procedural decisions.
🔹 Types of Issues Reviewed & Corresponding Standards
| Issue Type | Standard of Review | Description |
|---|---|---|
| Findings of Fact | Substantial Evidence | Courts uphold if supported by substantial evidence on the record. |
| Legal Questions | De Novo or Chevron Deference | Courts review de novo unless agency interpretations of statutes get Chevron deference. |
| Procedural Matters | Abuse of Discretion | Courts defer unless procedure violates law or is arbitrary. |
| Constitutional Issues | De Novo | Courts independently review constitutional claims. |
🔷 Key Cases Illustrating Standards of Review
1. Universal Camera Corp. v. NLRB (1951)
Citation: 340 U.S. 474
Facts:
The Supreme Court clarified the standard for reviewing agency findings of fact in formal adjudications.
Holding:
The court held that findings must be supported by "substantial evidence on the record considered as a whole."
The reviewing court must consider contradictory evidence and the agency’s explanation.
Significance:
Established the “substantial evidence” standard as the baseline for factual review in formal adjudications.
Ensured courts give due weight to agency expertise but can still examine the record comprehensively.
2. Citizens to Preserve Overton Park v. Volpe (1971)
Citation: 401 U.S. 402
Facts:
Agency decision to approve highway construction through a park was challenged.
Holding:
The Court ruled that agency decisions are reviewed for abuse of discretion.
Requires courts to ensure the agency examined relevant data and articulated a rational connection between facts and decision.
Significance:
Introduced the “arbitrary and capricious” standard for reviewing agency actions outside formal adjudications.
Courts must ensure decisions are not irrational or unexplained.
3. SEC v. Chenery Corp. (1947)
Citation: 332 U.S. 194
Facts:
The SEC made a decision based on reasons different from those initially stated.
Holding:
Courts review only the grounds on which the agency relied at the time.
Agency decisions must be based on adequate reasoning within the record.
Significance:
Established the principle that agencies cannot defend decisions on new grounds in court.
Reinforced judicial review based on the administrative record.
4. Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. (1984)
Citation: 467 U.S. 837
Facts:
The EPA interpreted an ambiguous statutory term during adjudication.
Holding:
Courts defer to an agency’s reasonable statutory interpretation if Congress has not spoken clearly (Chevron deference).
Significance:
Extended Chevron deference to agency adjudications involving statutory interpretation.
Clarified when courts should defer to agencies on legal issues.
5. Vermont Yankee Nuclear Power Corp. v. NRDC (1978)
Citation: 435 U.S. 519
Facts:
Petitioners challenged the NRC’s adjudicative procedures.
Holding:
The Court emphasized that courts cannot impose additional procedural requirements beyond those mandated by statute or APA.
Significance:
Limited judicial review of procedural matters to ensure agency autonomy.
Courts review procedural questions for abuse of discretion only.
6. Browder v. Director, Illinois Dept. of Corrections (1978)
Citation: 434 U.S. 257
Facts:
Review of agency’s factual findings in prisoner parole adjudication.
Holding:
Reinforced that substantial evidence is the standard to uphold factual findings.
Significance:
Confirmed application of substantial evidence standard to formal agency adjudications involving individual rights.
7. Motor Vehicle Manufacturers Ass’n v. State Farm (1983)
Citation: 463 U.S. 29
Facts:
Review of agency rulemaking decision, but standard also relevant for reviewing agency adjudications involving policy judgments.
Holding:
The agency’s decision must not be arbitrary, capricious, or an abuse of discretion.
Significance:
Clarified and reinforced the arbitrary and capricious standard for policy decisions in adjudications.
🔷 Summary Table of Standards of Review for Adjudications
| Issue | Standard of Review | Case Example |
|---|---|---|
| Findings of Fact | Substantial Evidence | Universal Camera, Browder |
| Legal Questions (statutory interpretation) | Chevron Deference or De Novo | Chevron |
| Procedural Issues | Abuse of Discretion | Overton Park, Vermont Yankee |
| Constitutional Claims | De Novo | Various constitutional cases |
🔷 Practical Application of Standards
Courts uphold agency factual findings if supported by the record, even if there is conflicting evidence.
Legal conclusions are reviewed more strictly but with deference if the agency interprets statutes within its expertise.
Courts will overturn agency decisions if they are arbitrary, capricious, or an abuse of discretion.
Procedural compliance is reviewed to ensure fairness and legality, but courts do not second-guess agency procedural choices lightly.
Constitutional issues get independent review.
🔷 Conclusion
The standard of review for agency adjudications balances:
Respect for agency expertise and policy judgments.
Protection of individual rights and legal correctness.
Ensuring agency decisions are reasoned, supported, and lawful.
The judicial role is to ensure agencies do not act arbitrarily or beyond their authority, but without substituting court judgment for agency expertise.
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