Bowman Transp., Inc. v. Ark.-Best Freight Sys.

Bowman Transp., Inc. v. Ark.-Best Freight Sys., Inc., 419 U.S. 281, 290 (1974), is a decision by the U.S. Supreme Court which held that the rational-basis standard is sufficient to satisfy the "arbitrary and capricious" test under administrative law:

“

[W]e can discern in the Commission's opinion a rational basis for its treatment of the evidence, and the ‘arbitrary and capricious’ test does not require more.

”

Id.

The Court reversed, under the APA, on a direct appeal from a final judgment of a three-judge District Court, 28 U. S. C. §§ 1253, 2101, which had invalidated an order of the Interstate Commerce Commission. The Court explained:

“

Ten applications of motor carriers to conduct general commodities operations between points in the Southwest and Southeast were consolidated in one proceeding. Three additional applicants were allowed to intervene. The hearing examiners, after extensive hearings, rejected each application. The Commission granted three of the applications of appellant carriers. Appellees, competing carriers, brought an action in the District Court, 28 U. S. C. § 1336, to suspend, enjoin, and annul that portion of the order of the Commission that authorizes issuance of certificates of public convenience and necessity to Red Ball, Bowman, and Johnson.

”

Bowman Transp., Inc. v. Ark.-Best Freight Sys., Inc., 419 U.S. 281, 283, 95 S. Ct. 438, 440-41 (1974).

The District Court refused to enforce the Commission's order based on its holding that the findings and conclusions of the Commission were arbitrary, capricious, and without rational basis within the meaning of the Administrative Procedure Act, 5 U.S.C. § 706. The District Court even refused to remand the case, believing that no useful purpose would be served, 364 F.Supp. 1239, 1264.

The Supreme Court reversed the District Court.