Friday, November 01, 2019 2:46:16 AM
meaningful relief would require wreaking havoc on an
otherwise well-functioning regulatory scheme, or vacating an agency action that would be statutorily
proper in the ordinary course. All it would entail is
making several accounting adjustments on the books
of the companies and Treasury. Vacatur of unlawful
agency action is a common remedy under the Administrative Procedure Act, see 5 U.S.C. § 706(2), and in
this case that remedy is warranted. This Court should
grant the petition and give petitioners the meaningful
relief they seek.
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