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The parties dispute the legal effect of a contested transaction. An agency imposed sanctions after combining investigation, rulemaking, and adjudication steps. Another actor changed position after relying on the relevant statement, document, or official action. The parties disagree about the legal effect of those facts. Which analysis is most consistent with these facts?

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The court should resolve the dispute by applying the operative rule to the material facts: The answer should identify the governing rule for Poder de investigacion and apply it to the operative facts. Resolve the dispute on equitable fairness alone without identifying the governing doctrine or its limits. Stop the analysis once the proponent states a plausible rule, without addressing the strongest counterargument. Assume the doctrine applies because one element appears satisfied, even if the remaining elements are contested.

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