---
title: "Separate the file facts from the federal review grounds"
url: "https://ailawframework.com/practice/administrative-and-public-law/build-a-lawful-decision-checklist-for-an-agency-client/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A31-T1-R5-US"
practice_area: "Administrative & Public Law"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Separate the file facts from the federal review grounds

> Make a fact table of the decision date, the decision-maker named, and the procedure the file records. Do not mark a review ground as met, and write no sentence of advice.

Canonical page: https://ailawframework.com/practice/administrative-and-public-law/build-a-lawful-decision-checklist-for-an-agency-client/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Administrative & Public Law](https://ailawframework.com/practice/administrative-and-public-law.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | Make a fact table of the decision date, the decision-maker named, and the procedure the file records. Do not mark a review ground as met, and write no sentence of advice. |
| What the lawyer must review | 5 U.S.C. § 706 sets the scope of review, including arbitrary or capricious action, action in excess of statutory authority, action without the procedure required by law, and, in a case heard on the record under §§ 556 and 557, a lack of substantial evidence. Section 704 requires final agency action. You decide which ground, if any, is arguable. The tool does not. |
| Written for | United States |
| Applies to | [Build a lawful-decision checklist for an agency client](https://ailawframework.com/practice/administrative-and-public-law/build-a-lawful-decision-checklist-for-an-agency-client.md) |

## Checking plan

- What the AI does: Make a fact table of the decision date, the decision-maker named, and the procedure the file records. Do not mark a review ground as met, and write no sentence of advice.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The fact table is not a checklist with boxes ticked. Ticking a ground is a legal conclusion.
- Organic statutes often set a shorter time for judicial review. None of those periods was opened.

## Sources

- [5 U.S.C. § 706, Scope of review](https://www.law.cornell.edu/uscode/text/5/706) (checked 2026-10-22)
- [5 U.S.C. § 704, Actions reviewable](https://www.law.cornell.edu/uscode/text/5/704) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*