Author Archives: Jennifer Nou

The SEC’s Subdelegated Appointments Power

by Jennifer Nou — Friday, Dec. 1, 2017@Jennifer_Nou

Yesterday, the Securities and Exchange Commission (SEC) hedged its bets: it issued an order ratifying the prior appointments of its administrative law judges (ALJs). The order also called for fresh proceedings in pending actions before these newly-blessed ALJs. The SEC did all of this to “put to rest” the argument — now pursued by the […]

The CBO-CBA Analogy, or What Wonks Could Learn from Each Other

by Jennifer Nou — Sunday, Mar. 19, 2017@Jennifer_Nou

The Congressional Budget Office (CBO) recently released its long-awaited report on the likely budgetary effects of the American Health Care Act. The legislative counterpart to the White House’s Office of Management and Budget, CBO estimates how federal spending and revenues would change as a result of proposed legislative bills. The resulting Republican talking points were […]

Taming the Shallow State, by Jennifer Nou

by Jennifer Nou — Tuesday, Feb. 28, 2017@Jennifer_Nou

The gloves have now come off in the battle between President Trump and an increasingly alarmed federal bureaucracy. EPA employees are in the streets. The National Park Service is sending out insubordinate tweets. Intelligence agencies are not just leaking, they’re gushing. Bureaucratic resistance is, of course, not new. But what does seem unprecedented is the […]

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Bureaucratic Resistance from Below, by Jennifer Nou

by Jennifer Nou — Wednesday, Nov. 16, 2016@Jennifer_Nou

Donald Trump is the President-Elect with both houses of Congress at his disposal. He promises judicial nominations to help bring the courts under his sway. He invokes authoritarian rulers as paragons of leadership. Trump’s instinctive reaction to dissent is not to listen, but to destroy. And what hopes lie in the moderating norms of the […]

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