Review of factual findings in agency adjudications
🔎 What Is Review of Factual Findings?
When an agency makes a decision (in a formal or informal adjudication), it often includes factual findings—what happened, who did what, what evidence shows.
Judicial review: Courts review these findings to decide if they were supported by substantial evidence and were not arbitrary.
Unlike pure questions of law, factual findings get strong deference.
The main test is often the “substantial evidence” standard under the Administrative Procedure Act (APA).
⚖️ Legal Standards
Substantial Evidence Standard (APA §706(2)(E)):
Courts uphold agency findings if supported by “such relevant evidence as a reasonable mind might accept as adequate.”
Arbitrary and Capricious Review:
Even with evidence, courts can overturn if the agency ignored important evidence or made illogical conclusions.
Deference to Agency Expertise:
Courts usually do not re-weigh evidence or substitute their judgment.
📚 Case Law: More Than Five Detailed Cases
✅ 1. Universal Camera Corp. v. NLRB (1951)
Court: U.S. Supreme Court
Facts: NLRB found a company guilty of unfair labor practices based on factual determinations.
Issue: What is the standard for reviewing agency factual findings?
Holding: Introduced the “substantial evidence” standard, meaning courts must look at the whole record, including evidence that detracts from the agency’s conclusion.
Significance: Landmark case defining judicial deference to agency fact-finding.
✅ 2. Motor Vehicle Manufacturers Association v. State Farm (1983)
Court: U.S. Supreme Court
Facts: NHTSA rescinded a mandatory seatbelt standard.
Issue: Was the agency’s factual basis for rescinding the rule reasonable?
Holding: The court struck down the rescission as arbitrary and capricious because the agency ignored evidence supporting safety benefits.
Significance: Clarified that factual findings must be reasoned and consider contrary evidence.
✅ 3. SEC v. Chenery Corp. (1947)
Court: U.S. Supreme Court
Facts: SEC made factual findings in an administrative adjudication about stock sales.
Issue: Can courts uphold an agency decision on a new rationale not stated by the agency?
Holding: No, courts review the agency’s original rationale and facts, not new justifications.
Significance: Ensured factual review focuses on agency’s actual findings and reasoning.
✅ 4. Butte County v. Hogen (1988)
Court: Ninth Circuit
Facts: Environmental agency made factual findings about pollution sources.
Issue: Was the agency’s factual finding supported by evidence?
Holding: Court upheld the agency’s findings, emphasizing deference to agency expertise in technical matters.
Significance: Reinforced strong judicial deference for technical factual findings.
✅ 5. Citizens to Preserve Overton Park v. Volpe (1971)
Court: U.S. Supreme Court
Facts: DOT approved a highway route over local objections.
Issue: Did the agency’s factual findings about route necessity withstand review?
Holding: The court required a thorough review to ensure the agency did not act arbitrarily but did not substitute its judgment.
Significance: Established that courts can require agencies to explain their factual conclusions clearly.
✅ 6. NLRB v. Columbian Enameling & Stamping Co. (1939)
Court: U.S. Supreme Court
Facts: NLRB found a labor violation based on witness credibility.
Issue: Can courts question agency credibility determinations?
Holding: No; credibility assessments are for the agency, and courts defer unless findings lack any support.
Significance: Credibility determinations are virtually unreviewable if reasonable.
🧠 Summary Table: Review of Factual Findings
| Principle | Case | Meaning |
|---|---|---|
| Substantial evidence standard | Universal Camera | Courts review the entire record |
| Must consider contrary evidence | State Farm | No ignoring important evidence |
| Courts don’t make new justifications | Chenery | Focus on agency’s original facts |
| Deference to technical expertise | Butte County | Agencies get leeway on complex facts |
| Agencies must explain findings | Overton Park | Courts ensure agency reasoned decisions |
| Credibility calls go to agency | Columbian Enameling | Courts defer on witness credibility |
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