The following excerpt is from Covenant v. Barr, 964 F.3d 832 (9th Cir. 2020):
Under the Administrative Procedure Act, "[w]hen an administrative agency sets policy, it must provide a reasoned explanation for its action." Judulang v. Holder , 565 U.S. 42, 45, 132 S.Ct. 476, 181 L.Ed.2d 449 (2011). "That is not a high bar, but it is an unwavering one." Id. To clear it, an agency must "articulate a satisfactory explanation for its action including a rational connection between the facts found and the choice made, " and it may not "entirely
[964 F.3d 859]
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