The Ninth Circuit’s October 27, 2026 agency opinion in docket 25-2445 is a useful reminder that appellate review of agency action turns less on whether the court agrees with the agency’s policy choice and more on whether the agency adequately explained itself, followed the governing statute, and built a defensible administrative record.

Although the case arises in the agency-review posture rather than ordinary civil litigation, the opinion has practical significance for lawyers handling petitions for review, regulated entities challenging federal action, and agency counsel defending administrative decisions.