The Federal Aviation Agency (FAA), under the direction of its administrator Elwood R. Quesada (defendant), promulgated a regulation that required commercial pilots to retire at age 60. The FAA conducted studies and research to determine the appropriate cutoff age for pilots. The general public was afforded an opportunity to submit comments on the proposed regulation. The Air Line Pilots Association (ALPA) (plaintiff) submitted a written comment during the rulemaking process. The process did not include a hearing because Quesada determined it would not serve a useful purpose, which he was entitled to decide under the Administrative Procedure Act (APA). The ALPA claimed that the APA required the FAA to hold an adjudicative hearing for every pilot affected by the new regulation or, alternatively, that the Federal Aviation Act required a hearing in which each pilot could submit evidence regarding the fairness of the regulation. The ALPA sought a preliminary injunction in the lower court, which was denied. The ALPA appealed to the United States Court of Appeals for the Second Circuit.