Mullin v. Doe · ¶68

This argument also contradicts general administrative- law principles. In APA cases, an agency’s subsidiary decisions merge into the final agency action, which is then subject to review. See Army Corps of Engineers v. Hawkes Co., 578 U. S. 590, 597–598 (2016). If the final agency action is unreviewable, then so too are subsidiary determinations. See Amgen, Inc. v. Smith, 357 F. 3d 103, 113 (CADC 2004); DCH Regional Medical Center v. Azar, 925 F. 3d 503, 506 (CADC 2019). This important principle ensures that challengers cannot avoid a judicial-review bar by creative pleading or clever lawyering.

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