agency action
-    formal adjudication or rulemaking – substantial evidence
-    substantial evidence in light of ENTIRE record (Univ. Camera Corp. v. NLRB)
-    court should uphold if reasonable mind would accept evidence as adequate to support a conclusion
-    deference to ALJ if decision based on witness credibility
-    informal rulemaking – arbitrary and capricious
-    take a “hard look” at whole record (See Overton Park)
-    need evidence (See Automotive Parts v. Boyd)
-    rejected post hoc rationalizations (Nat’l Tire Dealers & Retreaders)
-    procedural standard b/c consider all evidence
-    JM – not sure standard is different than substantial evidence
-    same standard for rescission (See State Farm)
-    new issues or procedural inadequacies in agency action – de novo