This section contains the nature of the case and procedural background.

The FTC leveled charges against eight oil companies (D) that they had engaged in unfair methods of competition in connection with the OPEC oil boycott during the late 1970s. Ds moved to dismiss the complaint asserting that is had been filed as a result of political pressure from Congress, the commission failed to develop information that might sustain its charges, that the charges had no basis in fact, and that the statutory requirement of reason to believe has not been satisfied. The commission denied the motion and Ds sought judicial review of the commission's refusal to dismiss the complaint. D brought an action against P asserting that P had issued the complaint without having 'reason to believe' that the company was violating the Federal Trade Commission Act. The District Court dismissed the complaint, but the Court of Appeals reversed, holding that P's issuance of the complaint constituted 'final agency action' under 10(c) of the Administrative Procedure Act. The Supreme Court granted certiorari.

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