Gripum, LLC v. Food and Drug Administration
AdministrativeLaw JusticiabilityDoctri
What level of judicial deference is afforded to administrative agencies with conflicts of interest?
QUESTIONS PRESENTED The questions presented for review are: (1) What level of judicial deference, if any, is afforded the determinations of administrative agencies which have a conflict of interest vis-dvis regulated parties; (2) Whether an agency violates the Administrative Procedure Act when it changes a key evidentiary requirement without prior notice to regulated parties after the expiration of the deadline for complying with such new requirement; and (3) Whether an agency violates the Administrative Procedure Act when it rigidly adheres to a presumption which is overbroad and lacks evidentiary support.