S. 33 — SOPRA

This section restructures 5 U.S.C. 706—the Administrative Procedure Act (APA) provision specifying the scope of judicial review of agency actions—into subsections (a), (b), and (c). It revises new subsection (a) to require reviewing courts to decide de novo all relevant questions of law, including agency interpretations of constitutional and statutory provisions, rules, interpretative rules, general statements of policy, and other agency guidance documents (replacing prior authority to decide such questions without specifying de novo review). New subsection (a) applies in any judicial review of agency action authorized by law notwithstanding any other provision of law, and no law may exempt such actions except by specific reference to the section. (Thus, courts must independently determine the meaning of all legal authorities cited by agencies without deference.)