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8 208, 212. The Court identified three considerations designed to aid in that inquiry, commonly known now as the Thunder Basin factors. First, could precluding district court jurisdiction “foreclose all meaningful judicial review” of the claim? Id., at 212–213. Next, is the claim “wholly collateral to [the] statute’s review provisions”? Id., at 212 (internal quotation marks omitted). And last, is the claim “outside the agency’s expertise”? Ibid. When the answer to all three questions is yes, “we presume that Congress does not intend to limit jurisdiction.” Free Enterprise Fund, 561 U. S., at 489. But the same conclusion might follow if the factors point in different directions. The ultimate question is how best to understand what Congress has done—whether the statutory review scheme, though exclusive where it applies, reaches the claim in question. The first Thunder Basin factor recognizes that Congress rarely allows claims about agency action to escape effective judicial review. See, e.g., Bowen v. Michigan Academy of Family Physicians, 476 U. S. 667, 670 (1986). The second and third reflect in related ways the point of special review provisions—to give the agency a heightened role in the matters it customarily handles, and can apply distinctive knowledge to.

This Court has twice held specific claims to fit within a statutory review scheme, based on the Thunder Basin factors. In Thunder Basin itself, a coal company subject to the Mine Act filed suit in district court instead of asserting its claims—as a statutory scheme prescribed—before a mine safety commission and then (if needed) a court of appeals. The crux of the dispute concerned the company’s refusal to provide employee-designated union officials with access to the workplace, as the Mine Act apparently required. The company claimed a right to exclude the officials under another statute; it also objected on due process grounds to the agency’s imposing a fine before holding a hearing. See 510 U. S., at 205; see also Elgin, 567 U. S., at 17, n. 6. We held