They could argue it is an arbitrary or capricious action by the agency: https://www.law.cornell.edu/uscode/text/5/706 https://www.law.cornell.edu/uscode/text/5/

They could argue it is an arbitrary or capricious action by the agency: https://www.law.cornell.edu/uscode/text/5/706 https://www.law.cornell.edu/uscode/text/5/706 If Harvard has maintained approval for international students, and Harvard's policies with respect to the approval haven't changed recently, then withdrawing approval would be arbitrary.