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or articulating a reasoned basis for its decision, DASCO found
“no justification” for relief. The District Court, in its
capacity as a reviewing court under the Administrative Procedure
Act (APA), summarily affirmed the ASCS’s determination. In so
doing, the District Court relied solely on counsel’s
representations and other materials attached to the ASCS’s motion
to affirm and did not actually examine the administrative record
or conduct the thorough review required by the APA. Id. at 1565.
The Court of Appeals concluded under the circumstances that the
District Court “employed neither the procedure nor the standard
of review required when agency action is challenged on appeal to
a district court in this circuit.” Id.
The facts of Olenhouse are distinguishable from the facts of
this case. Olenhouse involved a review of an agency
determination that was subject to the APA. Although the District
Court was obligated under the APA to conduct a detailed and
thorough review of the administrative record and the parties’
arguments regarding it, the Court of Appeals concluded that the
District Court did not do so. Over the objections of the
aggrieved party, the District Court relied on the agency’s
representations regarding the record, without conducting the kind
of independent and detailed review that the APA required. After
concluding that the District Court was required to do more than
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Last modified: March 27, 2008