Training explains when agencies can change an ALJ’s Proposal for Decision under Texas law
At an executive-committee training, the presenter explained how agencies may modify an administrative law judge's Proposal for Decision (PFD) under the Texas Administrative Procedure Act, stressing limits on changing basic facts, greater discretion on sanctions, and the litigation risks of altering findings.
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Speaker 1, the session presenter, told the executive committee that “a PFD is a recommendation by the ALJ” and walked attendees through what parts of a PFD an agency can lawfully change and why those limits matter. The presentation defined a PFD’s core elements—findings of fact, conclusions of law, and recommended sanctions—and emphasized that agencies usually may not alter basic factual findings established by the ALJ’s hearing record.
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