Appeal No. 2001-1863
Application No. 08/603,665
Deferential judicial review under the Administrative Procedure
Act does not relieve the agency of its obligation to develop
an evidentiary basis for its findings. To the contrary, the
Administrative Procedure Act reinforces this obligation. See,
e.g., Motor Vehicle Manufacturers Ass’n v. State Farm Mutual
Automobile Ins. Co., 463 U.S. 29, 43 (1983) (“the agency must
examine the relevant data and articulate a satisfactory
explanation for its action including a ‘rational connection
between the facts found and the choice made.’”)(quoting
Burlington Truck Lines v. United States, 371 U.S. 156, 168
(1962)); Securities & Exchange Comm'n v. Chenery Corp., 318
U.S. 80, 94 (1943) (“The orderly function of the process of
review requires that the grounds upon which the administrative
agency acted are clearly disclosed and adequately
sustained.”).
The foundation of the principle of judicial deference to the
rulings of agency tribunals is that the tribunal has
specialized knowledge and expertise, such that when reasoned
findings are made, a reviewing court may confidently defer to
the agency's application of its knowledge in its area of
expertise. Reasoned findings are critical to the performance
of agency functions and judicial reliance on agency
competence. See Baltimore and Ohio R. R. Co. v. Aberdeen &
Rockfish R. R. Co., 393 U.S. 87, 91-92 (1968)(absent reasoned
findings based on substantial evidence effective review would
become lost “in the haze of so-called expertise”). . . . The
Board's findings must extend to all material facts and must
be documented on the record, lest the "haze of so-called
expertise" acquire insulation from accountability.
Clearly, Lee reiterates that a reasoned conclusion by the
examiner must be supported by some evidence in the administrative
record.
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