Court of Appeals for the D.C. Circuit May 11, 2018, No. 18–cv–00346 (KBJ) (Policy & Research, LLC v. U.S. Dep't of Health & Human Servs.)

KETANJI BROWN JACKSON, United States District Judge

As far as the Administrative Procedures Act, 5 U.S.C. § 701 et seq. , is concerned, this much is clear: a federal agency that changes course abruptly without a well-reasoned explanation for its decision or that acts contrary to its own regulations is subject to having a federal court vacate its action as "arbitrary [and] capricious," id.