The following is an example of how courts review agency decisions when the agency has reversed a previous policy position. In two of the cases -- State Farm and Mass v. EPA -- the change in the agency's position coincided directly with a change in Presidential Administration. In all of the cases some members of the Court acknowledge the role of politics in agency decision-making, though they disagree as to whether that should change the judicial review calculus.
(1) Motor Vehicles Manufacturers Association v. State Farm, 463 U.S. 29 (1983), link to full case in Google Scholar
You only need to read parts I, II, V, VI, and VII of the opinion. We will not be discussing the standing analysis).
(4) 5 U.S.C. section 706 (the judicial review section of the Administrative Procedure Act)
The readings below involve the following:
Encino Motorcars, LLC v. Navarro, No. 15-415, 579 U.S. ___, 136 S.Ct. 2117 (June 20, 2016), link to Supreme Court website
Regulatory Accountability Act of 2017, H.R. 5, 115th Cong., link to Congress.gov.
Christopher v. Smithkline Beecham Corp., 567 U.S. ___, 132 S.Ct. 2156 (2012), link to Supreme Court website.
(This case will expose you to Auer deference and to how Auer deference may be inapplicable when an agency’s change in position would result in unfair surprise to those who are regulated. )
Heckler v. Chaney, 470 U.S. 821 (1985), Google Scholar link
(This case sets up a general presumption of non-reviewability for non-enforcement decisions.)
Connor Raso, Congress may tell courts to ignore regulatory agencies’ reasoning, but will it matter?, Brookings, Jan. 27, 2017.
William N. Eskridge Jr. & Connor Raso, Chevron as a Canon, not a Precedent: An Empirical Test of what Motivates Judges in Agency Deference Cases, 110 Colum. L. Rev. 1727 (2010).