IANAL, but this isn’t an administrative order, it’s a decision by an agency in a proceeding. It’s analogous to appealing a court judgement; you appeal by bringi

IANAL, but this isn’t an administrative order, it’s a decision by an agency in a proceeding. It’s analogous to appealing a court judgement; you appeal by bringing the same dispute (with the same parties) to a higher court, not by launching a lawsuit against the lower court. The USA is similar.