What is the test for an administrative agency to justify its actions under the Administrative Procedure Act?

MultiRegion, United States of America

The following excerpt is from Covenant v. Barr, 964 F.3d 832 (9th Cir. 2020):

Under the Administrative Procedure Act, "[w]hen an administrative agency sets policy, it must provide a reasoned explanation for its action." Judulang v. Holder , 565 U.S. 42, 45, 132 S.Ct. 476, 181 L.Ed.2d 449 (2011). "That is not a high bar, but it is an unwavering one." Id. To clear it, an agency must "articulate a satisfactory explanation for its action including a rational connection between the facts found and the choice made, " and it may not "entirely

[964 F.3d 859]

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