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However, the APA also recognized the need for courts to show appropriate deference to agency expertise, particularly in technical areas where agencies possessed specialized knowledge that judges lacked. This deference doctrine has evolved through decades of judicial decisions, creating a complex framework that attempts to balance respect for agency expertise with meaningful judicial oversight.
The challenge has been determining when deference is appropriate and when it becomes abdication of judicial responsibility. Courts have developed various standards of review—from highly deferential approaches that essentially rubber-stamp agency decisions to more searching inquiries that second-guess administrative determinations.
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