Admin Law Practice Exam

How does the requirement to consider all relevant factors influence an agency’s decision under the APA?

Consideration of factors is optional. A failure to consider relevant factors can render the decision arbitrary and capricious. Consideration of factors guarantees a favorable outcome. Only factors listed in the statute matter; others are ignored.

Correct Answer:

A failure to consider relevant factors can render the decision arbitrary and capricious.

Explanation:

Under the APA, agency decisions must be grounded in a full, reasoned consideration of all factors that bear on the issue, with a rational connection between the facts and the chosen action. If an agency ignores a relevant factor—whether it’s statutory mandates, safety or public health data, economic impacts, or meaningful public inputs—the decision lacks a proper basis and can be found arbitrary and capricious. This requirement helps ensure decisions aren’t just discretionary preferences but are supported by the record and by applicable law. The SAMPLEother options misstate the duty: consideration isn’t optional, it doesn’t guarantee a favorable result, and agencies aren’t limited to only factors expressly listed in the statute.

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