I. Introduction

Thus far, we’ve considered courts reviewing agency actions for constitutionality, for compliance with congressional enactments, and for compliance with an agency’s own regulations. But other issues arise under Chapter Seven of the Administrative Procedure Act, or APA. These issues generally don’t implicate the court-made judicial-review standards such as those arising out of Bowles v. Seminole Rock and Sand Company, 325 U.S. 410 (1945) and Auer v. Robbins, 519 U.S. 452 (1997)....