Eric Friedman (plaintiff) was a commercial airline pilot. Friedman had been diagnosed with a form of diabetes. Friedman held a third-class certificate, which authorized him to pilot noncommercial flights. Friedman sought a first-class certificate, which was necessary to serve as a commercial airline pilot. The Federal Aviation Administration (FAA) (defendant) generally disqualified pilots with Friedman’s diagnosis from receiving a first-class certificate. A special medical authorization could be granted to an otherwise disqualified applicant if the applicant could demonstrate to the FAA that the necessary duties of the position could performed without endangering public safety. Friedman submitted an application for a first-class license to the FAA. The FAA responded, requesting that Friedman submit glucose monitoring records. The FAA stated that it would deny Friedman’s application if he did not submit the records. Friedman responded that he did not have such records and included letters from his physicians explaining that such monitoring was not medically necessary in his case. The FAA responded that it would not proceed with Friedman’s application until it received the glucose-monitoring information. The FAA also stated that Friedman’s application remained under consideration, and it granted Friedman a third-class certificate, which he already held. Friedman brought suit against the FAA, claiming that it had behaved in an arbitrary and capricious manner in assessing his request. The case was heard in federal court.