William Vester

---

Turning Square Corners: Regents and Arbitrary-and-Capricious Review’s Distributional Stakes

After the Supreme Court’s decision in Regents, courts have intensified their scrutiny of agency reversals that upset the expectations of regulatory beneficiaries. This Note defends that development and situates it within an underexplored history of courts calibrating the stringency of their review of agency action to distributional concerns.