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Association of Data Processing Service Organizations, Inc. v. Board of Governors of the Federal Reserve System

United States Court of Appeals for the District of Columbia Circuit

745 F.2d 677 (1984)

Relevant factsFree

The Federal Reserve Board (defendant) approved Citicorp's data-processing subsidiary petition (an adjudicatory action) and simultaneously amended a related regulation (a regulatory action) based on the same ALJ factual findings; ADPSO (plaintiff) argued the Board needed to show substantial evidence for both actions, not just the adjudicatory one.

IssueFree

Whether a federal regulatory action that is not supported by substantial evidence is impermissibly arbitrary and capricious.

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