- 8 - 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 thanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: March 27, 2008