Tag Archives: administrative procedure

Administrative Procedure as a Source of Agency Advantage

by Connor N. Raso — Thursday, June 25, 2015

Procedural requirements like the APA’s notice-and-comment process are often viewed as burdens on agencies to be avoided when possible. My new paper in the Administrative Law Review provides evidence for that view. But this view is not always correct (if it were, many questions in this area would be less interesting!). In some cases, agencies […]