I would say it depends now on what the kid and his family decide to do. $25k makes it big enough to warrant hiring an atty and going to court, where the argument can be made. The agency made a decision most likely based on what the kid said to them as he was being rescued, which was likely very self-deprecating and judgemental to begin with. The agents most likely used that testimony and reached a conclusion that they could successfully apply their regulation. My guess is there's going to be some attempt to backpedal out of whatever was said at the time of rescue and make a more objective statement that will then give the agency a better out for a germane application of their rules. A penitent attitude will likely go a long ways towards settling this. A non-responsive attitude will only invite enforcement. I don't think even the agency really expects the kid or his family to pay the full pop.