Review of agency action follows a path distinct from ordinary civil appeals.

Exhaustion. Administrative remedies must generally be pursued to completion before a court will hear the challenge, with narrow exceptions for futility, inadequacy and constitutional claims outside the agency’s competence.

Finality. The action must mark the consummation of the decision-making process and determine rights or obligations. Interim and advisory actions are not reviewable.

Standing requires injury within the zone of interests the statute protects.

The record. Review is confined to the administrative record, which the agency compiles. Supplementing it requires a showing that the agency omitted material it considered, or that the record is inadequate to permit review. Extra-record evidence is admitted rarely.

Standards. Factual findings for substantial evidence; agency action generally for whether it was arbitrary, capricious, an abuse of discretion or otherwise not in accordance with law; and questions of law with independent judgment, with the deference framework substantially narrowed.

Remedy. Vacatur and remand, or remand without vacatur where the defect may be curable and vacatur would be disruptive.

Deadlines. Petition periods are short and jurisdictional, and they run from publication or service depending on the statute.