In the case of Camp, Comptroller of the Currency v. Pitts et al., 1972, the U.S. Supreme Court ruled that a decision by federal banking authorities to deny an application for a new national bank charter was not subject to judicial review under the Administrative Procedure Act (APA). The applicants had sought review in district court after their application was denied by the Office of the Comptroller of Currency due to concerns about economic viability and management competence. The district court upheld this denial without holding an evidentiary hearing, which was affirmed on appeal. However, when brought before Supreme Court, it held that courts should uphold agency decisions if there is any valid reason for them based on evidence in administrative record at time decision made; hence no need for further hearings or explanations unless plaintiff can show irregularities in procedure or prejudicial bias.

In the dissenting opinion for Camp, Comptroller of the Currency v. Pitts et al., Justice Douglas argued that the Court's decision was a departure from established principles of administrative law and judicial review. He contended that when an agency denies an application without providing reasons or findings to support its decision, it is incumbent upon courts to ensure such decisions are not arbitrary or capricious by examining whether there is substantial evidence in the record supporting them. In this case, he believed that no such examination had been conducted by lower courts before affirming denial of bank charter application by Pitts and others. Furthermore, he expressed concern over potential abuse of discretion if agencies were allowed to justify their decisions post hoc during litigation rather than at time they made those decisions.