Only schools accredited by a nationally recognized accrediting agency or association qualify to receive federal student aid under the Higher Education Act (HEA). The secretary of the U.S. Department of Education (defendant) decides which accrediting agencies to recognize. HEA criteria include using effective standards to evaluate and monitor the quality of a school’s education, and performance indicators like student recruitment, admissions, and placement. Multiple investigations and lawsuits emerged accusing independent for-profit schools like ITT Technical and Corinthian of using fraudulent performance data and predatory practices. Those schools were accredited by the Accrediting Council for Independent Colleges and Schools (ACICS) (plaintiff). During its recognition status review, the department asked ACICS a series of questions. Part I asked about the problem schools. Part II asked how ACICS complied with HEA recognition standards, particularly as applied to the problem schools. ACICS responded to Part II with 36,000 pages of documents including a narrative, enforcement actions it initiated against dozens of schools, the problem schools’ accreditation applications, evaluations of those applications, and emails with the schools. The department report found that ACICS knew the problem schools committed widespread placement-rate fraud but failed to report it to the department. After reviewing the report and hearing both sides, the National Advisory Committee on Institutional Quality and Integrity voted to revoke ACICS’s recognition. ACICS appealed to the secretary of education, who found ACICS noncompliant with at least five recognition criteria without reviewing the 36,000 pages submitted. ACICS sued for judicial review of the secretary’s decision. Both sides moved for summary judgment.