Kristin Brooks Hope Center v. Federal Communications Commission, 393 U.S. App. D.C. 217

Kristin Brooks Hope Center operates toll-free suicide-prevention hotlines since 1998 and faced financial distress in 2006.
SAMHSA asked the FCC in 2006 to reassign five hotlines to SAMHSA; the FCC granted a temporary reassignment of three numbers in January 2007.
SAMHSA formally requested permanent reassignment in November 2007; the Center disputed ongoing emergency and fundraising efforts.
In October 2009 the FCC granted permanent reassignment to SAMHSA, citing long-term stability and quality of service.
The Center challenged the decision as arbitrary, capricious under 5 U.S.C. § 706(2)(A), and a taking under the Fifth Amendment, and the court vacated the reassignment.
The FCC’s reasoning relied on SAMHSA’s financial stability and service quality, but the court found the explanations insufficiently connected to the facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FCC's permanent reassignment was arbitrary and capricious	Center argues decision lacks rational basis	SAMHSA/FCC contend long-term stability and public safety justify transfer	Arbitrary and capricious; vacate and remand
Whether the FCC connection between facts found and choice made is rational	Center asserts FCC failed to connect evidence to outcome	FCC assert history of instability supports long-term transfer	Insufficient explanation; arbitrary decision
Whether the takings challenge is resolved given arbitrariness	Center asserts takings violation if property transferred without just compensation	Not addressed if arbitrariness disposed of the claim	Court does not reach takings issue

Burlington Truck Lines, Inc. v. United States, 371 U.S. 156 (1962) (requires a rational connection between the facts found and the agency's choice)
Motor Vehicle Manufacturers Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (1983) (agency must articulate a satisfactory explanation demonstrating reasoned decisionmaking)