arbitrary and capricious standard in Washington

2011Schneider, 116 Wash.App. at 716 , 66 P.3d 640 . ¶ 19 "Under the arbitrary and capricious standard, we will reverse only if an agency action was `willful and unreasoning, and taken without regard to the attending facts or circumstances.'" Schneider, 116 Wash.App. at 716 , 66 P.3d 640 (quoting ITT Rayonier, Inc. v. Dalman, 122 Wash.2d 801, 809 , 863 P.2d 64 (1993)).

2011Schneider, 116 Wash.App. at 716 , 66 P.3d 640 . ¶ 19 "Under the arbitrary and capricious standard, we will reverse only if an agency action was `willful and unreasoning, and taken without regard to the attending facts or circumstances.'" Schneider, 116 Wash.App. at 716 , 66 P.3d 640 (quoting ITT Rayonier, Inc. v. Dalman, 122 Wash.2d 801, 809 , 863 P.2d 64 (1993)).

1997"Under the arbitrary and capricious standard, this court only reverses willful and unreasoning action in disregard of facts and circumstances.” Washington Waste Sys., Inc. v. Clark County, 115 Wn.2d 74, 81 , 794 P.2d 508 (1990) (citing State v. Ford, 110 Wn.2d 827, 830 , 755 P.2d 806 (1988) and Abbenhaus v. City of Yakima, 89 Wn.2d 855, 858-59 , 576 P.2d 888 (1978)).

1997"Under the arbitrary and capricious standard, this court only reverses willful and unreasoning action in disregard of facts and circumstances.” Washington Waste Sys., Inc. v. Clark County, 115 Wn.2d 74, 81 , 794 P.2d 508 (1990) (citing State v. Ford, 110 Wn.2d 827, 830 , 755 P.2d 806 (1988) and Abbenhaus v. City of Yakima, 89 Wn.2d 855, 858-59 , 576 P.2d 888 (1978)).

2025The “substantial evidence standard, like the arbitrary and capricious standard, is ‘highly deferential’ to the agency fact finder.” Alpha Kappa Lambda Fraternity v. Wash. State Univ., 152 Wn.

2023“The substantial evidence standard, like the arbitrary and capricious standard, is ‘highly deferential’ to the agency fact finder.” Alpha Kappa Lambda Fraternity v. Wash. State Univ., 152 Wn.

2003Moreover, while in Neah Bay the court acknowledged that the older standard was analogous to the arbitrary and capricious standard, Neah Bay, 119 Wn.2d at 473 ; it did not state they were identical.

2003Moreover, while in Neah Bay the court acknowledged that the older standard was analogous to the arbitrary and capricious standard, Neah Bay, 119 Wash.2d at 473 , 832 P.2d 1310 ; it did not state they were identical.

2026“The scope of review under an arbitrary and capricious standard is very narrow, and the party asserting it carries a ‘heavy burden.’” Ass’n of Wash. Spirits & Wine Distribs. v. Liquor Control Bd., 182 Wn.2d 342, 359 , 340 P.3d 849 (2015) (internal quotation marks omitted) (quoting King County Pub.

2026“The scope of review under an arbitrary and capricious standard is very narrow, and the party asserting it carries a ‘heavy burden.’” Ass’n of Wash. Spirits & Wine Distribs. v. Liquor Control Bd., 182 Wn.2d 342, 359 , 340 P.3d 849 (2015) (internal quotation marks omitted) (quoting King County Pub.

2025Restraint of Dyer, 143 Wn.2d 384, 395-97 , 20 P.3d 907 (2001) (applying the arbitrary and capricious standard to review the Department’s denial of extended family visits).

2025The arbitrary and capricious standard is used to review a prison’s administrative decisions when constitutional rights are not involved because, “[a] broader scope of review is undesirable in that it would tend to undermine prison administrators’ decisions and lead to greater involvement of the courts in matters of internal prison discipline.” Dyer, 143 Wn.2d at 395-96 .

2025App. 401, 418 , 216 P.3d 451 (2009) (quoting ARCO Prods.

2023App. 401, 418 , 216 P.3d 451 (2009).

2013This court also observed, “That the courts may have reached a decision, made a choice or a conclusion different from that of the administrative agency, or taken wiser or more sensible action, does not empower them to do so.” Id. ¶37 In determining how much deference is given to an agency decision, it is also helpful to consider that actions reviewable under the APA are subject to an arbitrary and capricious standard. ¶38 In light of the arguments of the parties, this court’s history of reviewing administrative decisions, and the review afforded in other statutes dealing with necessity determin

2006Our courts, in actuality, review the declaration [of necessity] under the arbitrary and capricious standard, and we see no merit in applying a different label to that well-known test.”). f 86 Particularly relevant here is this court’s language in Postal Telegraph-Cable Co., 64 Wash. at 195 : It is sufficient to make a strong prima facie case, but when convincing evidence is adduced by the owner that the land sought is not reasonably necessary, and that a slight change of location to other of his land will equally meet the necessity of the taker and be of much less damage to the owner, then it

2010The statute is clear and express that the right of the Appellant to provide child care as a licensee is superseded by the right of children in care outside their homes to be assured of a safe and healthy environment.[ [2] ] *83 ¶ 38 The arbitrary and capricious test is a very narrow standard, and the one asserting it "must carry a heavy burden." In re Disciplinary Proceeding Against Brown, 94 Wash.App. 7, 16 , 972 P.2d 101 , review denied, 138 Wash.2d 1010 , 989 P.2d 1136 (1999).

2010The statute is clear and express that the right of the Appellant to provide child care as a licensee is superseded by the right of children in care outside their homes to be assured of a safe and healthy environment.[ [2] ] *83 ¶ 38 The arbitrary and capricious test is a very narrow standard, and the one asserting it "must carry a heavy burden." In re Disciplinary Proceeding Against Brown, 94 Wash.App. 7, 16 , 972 P.2d 101 , review denied, 138 Wash.2d 1010 , 989 P.2d 1136 (1999).

1993App. 250 , 666 P.2d 916 (1983). 5 Under the previous statute, case law held that subsection (4) and former subsection (5) together encompassed "essentially, the arbitrary and capricious standard used in nonwrit cases.” Murphy v. Seattle, 32 Wn.

1993Murphy v. Seattle, 32 Wn.

2025Restraint of Dyer, 143 Wn.2d 384, 395-97 , 20 P.3d 907 (2001) (applying the arbitrary and capricious standard to review the Department’s denial of extended family visits).

2025Restraint of Dyer, 143 Wn.2d 384, 391-92 , 20 P.3d 907 (2001).

2018Skagit County v. Dep’t of Ecology, 93 Wn.2d 742, 749 , 613 P.2d 115 (1980).

2018Skagit County v. Dep’t of Ecology, 93 Wn.2d 742, 749 , 613 P.2d 115 (1980).

1997"Under the arbitrary and capricious standard, this court only reverses willful and unreasoning action in disregard of facts and circumstances.” Washington Waste Sys., Inc. v. Clark County, 115 Wn.2d 74, 81 , 794 P.2d 508 (1990) (citing State v. Ford, 110 Wn.2d 827, 830 , 755 P.2d 806 (1988) and Abbenhaus v. City of Yakima, 89 Wn.2d 855, 858-59 , 576 P.2d 888 (1978)).

1997"Under the arbitrary and capricious standard, this court only reverses willful and unreasoning action in disregard of facts and circumstances.” Washington Waste Sys., Inc. v. Clark County, 115 Wn.2d 74, 81 , 794 P.2d 508 (1990) (citing State v. Ford, 110 Wn.2d 827, 830 , 755 P.2d 806 (1988) and Abbenhaus v. City of Yakima, 89 Wn.2d 855, 858-59 , 576 P.2d 888 (1978)).

2014Comm’n, 134 Wn.2d 48, 54 , 949 P.2d 1321 (1997) (where agency was required to “set rates which are fair, just, reasonable and sufficient,” the court utilized an arbitrary and capricious standard of review); Cole v. Wash. Utils. & Transp.

2014Comm'n, 134 Wn.2d 48, 54 , 949 P.2d 1321 (1997) (where agency was required to "set rates which are fair, just, reasonable and sufficient," the court utilized an arbitrary and capricious standard of review); Cole v. Wash. Utils. &Transp.

2014Comm’n, 134 Wn.2d 48, 54 , 949 P.2d 1321 (1997) (where agency was required to “set rates which are fair, just, reasonable and sufficient,” the court utilized an arbitrary and capricious standard of review); Cole v. Wash. Utils. & Transp.

2014Comm'n, 134 Wn.2d 48, 54 , 949 P.2d 1321 (1997) (where agency was required to "set rates which are fair, just, reasonable and sufficient," the court utilized an arbitrary and capricious standard of review); Cole v. Wash. Utils. &Transp.

2014Comm’n, 79 Wn.2d 302, 309 , 485 P.2d 71 (1971) (where agency was required to set rates that were just, fair, reasonable, and sufficient, the court was to utilize an arbitrary and capricious standard of review). ¶67 Given that RCW 54.04.045(3)(a)-(c) sets forth specific instructions for the District to follow, the trial court should have construed the meaning of those instructions without affording deference to the implementing entity.

2014Comm’n, 79 Wn.2d 302, 309 , 485 P.2d 71 (1971) (where agency was required to set rates that were just, fair, reasonable, and sufficient, the court was to utilize an arbitrary and capricious standard of review). ¶67 Given that RCW 54.04.045(3)(a)-(c) sets forth specific instructions for the District to follow, the trial court should have construed the meaning of those instructions without affording deference to the implementing entity.

2013Moreover, Coy does not address the fact that the City prevailed on his claim regarding the timeliness of the application process; although Coy eventually stipulated to the dismissal of that claim, he did not do so until after a motion for partial summary judgment on that issue had been submitted to the trial court. ¶19 “The amount of a fee award is discretionary, and will be overturned only for manifest abuse.” Boeing Co. v. Sierracin Corp., 108 Wn.2d 38, 65 , 738 P.2d 665 (1987).

2013Moreover, Coy does not address the fact that the City prevailed on his claim regarding the timeliness of the application process; although Coy eventually stipulated to the dismissal of that claim, he did not do so until after a motion for partial summary judgment on that issue had been submitted to the trial court. ¶19 “The amount of a fee award is discretionary, and will be overturned only for manifest abuse.” Boeing Co. v. Sierracin Corp., 108 Wn.2d 38, 65 , 738 P.2d 665 (1987).

2011Schneider, 116 Wash.App. at 716 , 66 P.3d 640 . ¶ 19 "Under the arbitrary and capricious standard, we will reverse only if an agency action was `willful and unreasoning, and taken without regard to the attending facts or circumstances.'" Schneider, 116 Wash.App. at 716 , 66 P.3d 640 (quoting ITT Rayonier, Inc. v. Dalman, 122 Wash.2d 801, 809 , 863 P.2d 64 (1993)).

2011Schneider, 116 Wash.App. at 716 , 66 P.3d 640 . ¶ 19 "Under the arbitrary and capricious standard, we will reverse only if an agency action was `willful and unreasoning, and taken without regard to the attending facts or circumstances.'" Schneider, 116 Wash.App. at 716 , 66 P.3d 640 (quoting ITT Rayonier, Inc. v. Dalman, 122 Wash.2d 801, 809 , 863 P.2d 64 (1993)).

2010The statute is clear and express that the right of the Appellant to provide child care as a licensee is superseded by the right of children in care outside their homes to be assured of a safe and healthy environment.[ [2] ] *83 ¶ 38 The arbitrary and capricious test is a very narrow standard, and the one asserting it "must carry a heavy burden." In re Disciplinary Proceeding Against Brown, 94 Wash.App. 7, 16 , 972 P.2d 101 , review denied, 138 Wash.2d 1010 , 989 P.2d 1136 (1999).

2010The statute is clear and express that the right of the Appellant to provide child care as a licensee is superseded by the right of children in care outside their homes to be assured of a safe and healthy environment.[ [2] ] *83 ¶ 38 The arbitrary and capricious test is a very narrow standard, and the one asserting it "must carry a heavy burden." In re Disciplinary Proceeding Against Brown, 94 Wash.App. 7, 16 , 972 P.2d 101 , review denied, 138 Wash.2d 1010 , 989 P.2d 1136 (1999).

2010Id. at 246-47, 76 P.3d 248 ; cf. Beck, 104 Wash. App. at 460-61 , 16 P.3d 692 . ¶ 22 The Guild's essential argument is that the issues raised by the County's challenge to the arbitrator's jurisdiction have already been decided.

2010Id. at 246-47; cf. Beck, 104 Wn.

2009For purposes of RCW 34.05.570(3)(e), substantial evidence is "a sufficient quantity of evidence to persuade a fair-minded person of the truth or correctness of the order." Callecod v. Wash. State Patrol, 84 Wash.App. 663, 673 , 929 P.2d 510 (1997). ¶ 48 The substantial evidence standard, like the arbitrary and capricious standard, is "highly deferential" to the agency fact finder.

2009App. 663, 673 , 929 P.2d 510 (1997). ¶47 The substantial evidence standard, like the arbitrary and capricious standard, is “highly deferential” to the agency fact finder.

2009Greenen v. Bd. of Accountancy, 126 Wn.

2009Greenen v. Bd. of Accountancy, 126 Wash.App. 824, 830 , 110 P.3d 224 (2005), review denied, 156 Wash.2d 1030 , 133 P.3d 474 (2006).

2009Mansour, 131 Wash. App. at 265-66 , 128 P.3d 1241 .

2008Mansour, 131 Wn.

2006Our courts, in actuality, review the declaration [of necessity] under the arbitrary and capricious standard, and we see no merit in applying a different label to that well-known test.”). f 86 Particularly relevant here is this court’s language in Postal Telegraph-Cable Co., 64 Wash. at 195 : It is sufficient to make a strong prima facie case, but when convincing evidence is adduced by the owner that the land sought is not reasonably necessary, and that a slight change of location to other of his land will equally meet the necessity of the taker and be of much less damage to the owner, then it

2006Our courts, in actuality, review the declaration [of necessity] under the arbitrary and capricious standard, and we see no merit in applying a different label to that well-known test."). ¶ 88 Particularly relevant here is this court's language in Postal Telegraph-Cable Co., 64 Wash. at 195 , 116 P. 855 : It is sufficient to make a strong prima facie case, but when convincing evidence is adduced by the owner that the land sought is not reasonably necessary, and that a slight change of location to other of his land will equally meet the necessity of the taker and be of much less damage to the ow