Preliminary Objections to Review
- Is action final (as required by APA 704)?
- 1) agency completed process AND 2) process had legal effect
- release of information not final action because no coercive effect (Flue-Cured Tobacco)
- inaction can be final
- need to show 1) immediate harm and 2) end of process (D.C. Circuit DDT Cases)
- doesn’t require change in legal position (AMP v. Gardner – review on whether drug or device)
- Is the action ripe?
- issues are fit for judicial review AND party seeking review would suffer hardship if review delayed until enforcement (Abbott Labs)
- Compare Toilet Goods – enforcement would clarify scope of regulation and will not cause plaintiffs to risk serious penalties
- Ohio Forestry v. Sierra Club – regulations that made logging more likely but did not authorize meant issue not ripe
- Has P exhausted administrative remedies? ( 704; Myers v. Bethlehem Shipbuilding)
- sometimes not enforced for fairness concerns (See McKart v. United States)
- not required to exhaust when question is constitutionality of process (Mathews v. Eldridge)
- only need to exhaust as far as statute says (Darby v. Cisneros)
- Is action moot?
- not moot unless behavior is not reasonably likely to occur (Laidlaw)
- voluntary cessation is not enough
- exception if claim is “capable of repetition yet evading review” (Doe v. Sullivan)
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