Sparkle Leah Sooknanan

Sooknanan reads statutory terms by their ordinary meaning and binding circuit gloss, and will not stretch informal agency communications into enforceable 'orders.' A litigant seeking to enforce agency action should identify a formal, authoritative command (a rule or compliance order), not 'workaday advice' or 'guidance' correspondence.

“This sort of 'workaday advice' by an agency official cannot be an actionable 'order' ... that gives rise to a claim under 49 U.S.C. 14704(a)(1).”

In APA review she enforces reasoned decisionmaking strictly even under deferential standards: an agency that overturns a favorable board recommendation must explain WHY it disagrees, engage the board's specific findings, and avoid conclusory boilerplate -- and the court will not accept counsel's post hoc rationalizations. Government counsel defending an agency reversal should ensure the decision itself addresses the contrary findings.

“these three grounds make it impossible for the Court to discern why he disagreed with the ABCMR; indeed, he never even addressed any of the eight factors relied on by the ABCMR ... This was a fatal mistake, even under the highly deferential standard”

She expects briefing tailored to the case and treats verbatim, unattributed copying from other decisions (without explaining how it applies) as a FORFEITURE of the argument. Counsel before her should adapt authority to the specific facts rather than 'regurgitate' boilerplate from analogous cases.

“By failing to do more than regurgitate largely inapplicable language from Pacito, the Plaintiffs have forfeited this claim. ... The Court declines 'to do counsel's work.'”