William Fox (defendant) was an administrator for the National Oceanic and Atmospheric Administration (the administration.) The administration, with Fox’s approval, issued a rule banning the use of draft gillnets for catching a specific type of fish. Several groups involved in the fishing industry (the groups) (plaintiffs) challenged the rule. Before Fox was appointed to the administration, he had been a strong advocate of the drift gillnet ban. Fox was the chairman of a commission that was an outspoken advocate of the ban, and he also wrote an article in favor of the ban. The groups argued that Fox thus had an unalterably closed mind when the ban was later under his consideration. Thus, the groups argued that Fox should have been disqualified from deciding on the ban. The trial court rejected the groups’ argument. The groups then appealed to the United States Court of Appeals for the District of Columbia Circuit.