American Horse Protection Association, Inc. v. Lyng

Rule of Law:

An agency's refusal to institute rulemaking proceedings is subject to judicial review under the "arbitrary and capricious" standard, and an agency must provide a reasoned explanation for its decision, particularly when presented with new evidence that undermines the factual predicate of an existing regulation.

Facts:

• Congress passed the Horse Protection Act to prohibit "soring," the practice of deliberately injuring show horses' limbs with devices like chains to create a prized high-stepping gait.
• The Secretary of Agriculture issued regulations that specifically banned heavy chains and action devices but permitted the use of lighter ones, subject to a general prohibition against any device that "causes or can reasonably be expected to cause" soreness.
• When issuing the initial rule, the agency acknowledged that the scientific basis for permitting lighter devices might change and commissioned a university study to gather more data.
• The commissioned study, conducted at Auburn University, concluded that some of the legally permitted devices, such as ten-ounce chains, caused lesions, bleeding, and inflammation, which meets the statutory definition of "sore."
• The American Horse Protection Association repeatedly petitioned the Department of Agriculture to initiate a new rulemaking to ban these harmful devices based on the Auburn study's findings.
• Internal agency communications acknowledged an "apparent inconsistency" between the existing regulations and the new research, and a draft of a new rule was prepared.
• Despite internal concerns and external petitions, the agency held the draft rule in abeyance and ultimately refused to initiate a new rulemaking, citing the need to observe industry self-regulation efforts.

Procedural Posture:

• The American Horse Protection Association (the 'Association') petitioned the Secretary of Agriculture to initiate rulemaking to amend regulations under the Horse Protection Act.
• The Secretary refused to initiate rulemaking, prompting the Association to file suit in the U.S. District Court for the District of Columbia, challenging the refusal as arbitrary and capricious.
• The District Court, a court of first instance, granted summary judgment in favor of the Secretary of Agriculture.
• The Association, as appellant, appealed the grant of summary judgment to the U.S. Court of Appeals for the D.C. Circuit, with the Secretary as appellee.