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Full-Text Articles in Administrative Law

State Bar Of California, Ashley Kearney, Bridget Fogarty Gramme May 2019

State Bar Of California, Ashley Kearney, Bridget Fogarty Gramme

California Regulatory Law Reporter

No abstract provided.


Deregulatory Splintering, William W. Buzbee May 2019

Deregulatory Splintering, William W. Buzbee

Chicago-Kent Law Review

When new administrations arrive and consider agency policy changes, they often must choose what actions to take in court or through regulatory process. They may seek to stay an existing regulation, rescind, or possibly replace it. This article assesses strategic uses of, and responses to, agencies that pursue deregulatory rollbacks through a splintered series of steps. Through such splintering, agencies sometimes seek to avoid direct apples-to-apples comparison of the baseline regulation and new proposal, also often squelching opportunities for comment. They may seek to achieve a deregulatory outcome without the full process, disclosure, and reason-giving that ordinarily must accompanying any …


The Regulatory Accountability Act And The Future Of Apa Revision, Ronald M. Levin May 2019

The Regulatory Accountability Act And The Future Of Apa Revision, Ronald M. Levin

Chicago-Kent Law Review

This article seeks to take stock of the Regulatory Accountability Act (RAA), a set of proposals to amend the Administrative Procedure Act (APA). House and Senate versions of the proposed Act have been pending in Congress since 2011, although the impending advent of Democratic control of the House may halt further progress on the bills in their present form. Some provisions in the RAA are desirable or at least supportable, because they would codify elements of current practice or make minor repairs to the APA. But other aspects of the bill are controversial and troubling. Among them are sections that …


V.24-2, 2019 Masthead May 2019

V.24-2, 2019 Masthead

California Regulatory Law Reporter

No abstract provided.


Medical Board Of California, Mason Bettencourt, Debra Jorgensen May 2019

Medical Board Of California, Mason Bettencourt, Debra Jorgensen

California Regulatory Law Reporter

No abstract provided.


Board Of Registered Nursing, Heather Morse, Debra Jorgensen May 2019

Board Of Registered Nursing, Heather Morse, Debra Jorgensen

California Regulatory Law Reporter

No abstract provided.


Veterinary Medical Board, Kelsey Burns, Betsy Gopinath May 2019

Veterinary Medical Board, Kelsey Burns, Betsy Gopinath

California Regulatory Law Reporter

No abstract provided.


Contractors’ State License Board, Natasha Pulido, Betsy Gopinath May 2019

Contractors’ State License Board, Natasha Pulido, Betsy Gopinath

California Regulatory Law Reporter

No abstract provided.


California Public Utilities Commission, Charles Kreuzberger, Thomas G. Routson, Negin Taleb, R. C. Fellmeth May 2019

California Public Utilities Commission, Charles Kreuzberger, Thomas G. Routson, Negin Taleb, R. C. Fellmeth

California Regulatory Law Reporter

No abstract provided.


Department Of Insurance, Sarah Marie Burgh, Joseph Cheng, Debra Jorgensen May 2019

Department Of Insurance, Sarah Marie Burgh, Joseph Cheng, Debra Jorgensen

California Regulatory Law Reporter

No abstract provided.


Bureau Of Cannabis Control, Nicole Cohen, Guinness Castello, R. C. Fellmeth May 2019

Bureau Of Cannabis Control, Nicole Cohen, Guinness Castello, R. C. Fellmeth

California Regulatory Law Reporter

No abstract provided.


Board Of Pharmacy, John Lacrosse, John Mysliwiec, Bridget Fogarty Gramme May 2019

Board Of Pharmacy, John Lacrosse, John Mysliwiec, Bridget Fogarty Gramme

California Regulatory Law Reporter

No abstract provided.


Bureau For Private Postsecondary Education, Junhee Park, R. C. Fellmeth May 2019

Bureau For Private Postsecondary Education, Junhee Park, R. C. Fellmeth

California Regulatory Law Reporter

No abstract provided.


Examining The Administrative Unworkability Of Final Agency Action Doctrine As Applied To The Native American Graves Protection And Repatriation Act, Adam Gerken May 2019

Examining The Administrative Unworkability Of Final Agency Action Doctrine As Applied To The Native American Graves Protection And Repatriation Act, Adam Gerken

Michigan Journal of Environmental & Administrative Law

The application of the Administrative Procedure Act (“APA”) to the Native American Graves Protection and Repatriation Act (“NAGPRA”) creates unique practical and doctrinal results. When considering the application of the current law concerning judicial review of final agency action under the APA to NAGPRA, it is evident that the law is simultaneously arbitrary and unclear. In the Ninth Circuit’s holding in Navajo Nation v. U.S. Department of the Interior, the Court applied final agency action doctrine in a manner that was legally correct but administratively unworkable. The Court’s opinion contravenes both the reasoning behind the APA final agency action …


Committee Of Bar Examiners, Samantha Steed, Bridget Fogarty Gramme May 2019

Committee Of Bar Examiners, Samantha Steed, Bridget Fogarty Gramme

California Regulatory Law Reporter

No abstract provided.


California Board Of Accountancy, Brian Attard, Debra Jorgensen May 2019

California Board Of Accountancy, Brian Attard, Debra Jorgensen

California Regulatory Law Reporter

No abstract provided.


The Locked Gates To Tension City: The Commission On Presidential Debates, The Fec, And The Two-Party System, Tommy La Voy May 2019

The Locked Gates To Tension City: The Commission On Presidential Debates, The Fec, And The Two-Party System, Tommy La Voy

Michigan Journal of Environmental & Administrative Law

Since John F. Kennedy and Richard Nixon walked into a Chicago television studio for the first general election presidential debate in 1960, candidate debates have been a fundamental aspect of presidential campaigns and have had broader effects on society at large. The Commission on Presidential Debates (“CPD”) has been in charge of organizing the general election debates since it was created in 1987 by the Democratic and Republican parties. In its tenure, the CPD has restricted its massive platform almost every election to the Republican and Democratic candidates through the use of criteria that seemingly follow the law’s requirement of …


The Shallow State: The Federal Communications Commission And The New Deal, Daniel R. Ernst May 2019

The Shallow State: The Federal Communications Commission And The New Deal, Daniel R. Ernst

Georgetown Law Faculty Publications and Other Works

American lawyers and law professors commonly turn to the New Deal for insights into the law and politics of today’s administrative state. Usually, they have looked to agencies created in the 1930s that became the foundation of the postwar political order. Some have celebrated these agencies; others have deplored them as the core of an elitist, antidemocratic Deep State. This article takes a different tack by studying the Federal Communications Commission, an agency created before the New Deal. For most of Franklin D. Roosevelt’s first two presidential terms, the FCC languished within the “Shallow State,” bossed about by patronage-seeking politicians, …


Agency Statutory Abnegation In The Deregulatory Playbook, William W. Buzbee May 2019

Agency Statutory Abnegation In The Deregulatory Playbook, William W. Buzbee

Georgetown Law Faculty Publications and Other Works

If an agency newly declares that it lacks statutory power previously claimed, how should such a move—what this article calls agency statutory abnegation—be reviewed? Given the array of strategies an agency might use to make a policy change or move the law in a deregulatory direction, why might statutory abnegation be chosen? After all, it is always a perilous and likely doctrinally disadvantageous strategy for agencies. Nonetheless, agencies from time to time have utilized statutory abnegation claims as part of their justification for deregulatory shifts. Actions by agencies during 2017 and 2018, under the administration of President Donald J. Trump, …


An Empirical Examination Of Agency Statutory Interpretation, Amy Semet May 2019

An Empirical Examination Of Agency Statutory Interpretation, Amy Semet

Journal Articles

How do administrative agencies interpret statutes? Despite the theoretical treatment scholars offer on how agencies construe statutes, far less is known empirically about administrative statutory interpretation even though agencies play a critical role in interpreting statutes. This Article looks behind the black box of agency statutory interpretation to review how administrative agencies use canons and other tools of statutory interpretation to decide cases. Surveying over 7,000 cases heard by the National Labor Relations Board (“NLRB”) from 1993-2016, I analyze the statutory methodologies the Board uses in its decisions in order to uncover patterns of how the Board interprets statutes over …


Statutory Interpretation, Administrative Deference, And The Law Of Stare Decisis, Randy J. Kozel May 2019

Statutory Interpretation, Administrative Deference, And The Law Of Stare Decisis, Randy J. Kozel

Journal Articles

This Article examines three facets of the relationship between statutory interpretation and the law of stare decisis: judicial interpretation, administrative interpretation, and interpretive methodology. In analyzing these issues, I emphasize the role of stare decisis in pursuing balance between past and present. That role admits of no distinction between statutory and constitutional decisions, calling into question the practice of giving superstrong deference to judicial interpretations of statutes. The pursuit of balance also suggests that one Supreme Court cannot bind future Justices to a wide-ranging interpretive methodology. As for rules requiring deference to administrative interpretations of statutes and regulations, they are …


Offshore Drilling: Combating Regulatory Uncertainty With Contract Law Protection, Jordan M. Steele May 2019

Offshore Drilling: Combating Regulatory Uncertainty With Contract Law Protection, Jordan M. Steele

Brooklyn Journal of Corporate, Financial & Commercial Law

Offshore drilling accounts for billions of dollars in tax revenue every year. It is a pillar of the energy industry and is crucial to the economy. A recent flurry of deregulation, accelerating with the arrival of the Trump administration, highlights the tremendous impact politics has upon the profitability of this sector. The Secretary of the Interior, under the direction of the President, wields the power to regulate and make determinations into where, when, and how private companies can drill offshore. These private companies have contracts with the government for the opportunity to produce and develop oil or gas on the …


The Nationalization Of The Dutch Owned Plantations In North Sumatra: To Whom The Communal Land Belong?, Edy Ikhsan Apr 2019

The Nationalization Of The Dutch Owned Plantations In North Sumatra: To Whom The Communal Land Belong?, Edy Ikhsan

Indonesia Law Review

This article has been developed through an analysis of primary and secondary sources concerning the nationalization’s policy of the Dutch enterprises in Indonesia as had been conducted by Soekarno’s regime back in 1958. The impact of this said policy has been so much felt very strongly to these days, most especially on the ex-concessionary lands of the Dutch enterprises in North Sumatera. The flaws made by the Indonesian government in interpreting the terminology of Concession to the Cultivation Rights on Lands, in the said nationalization policy, have created various endless conflicts among central and regional governments, state-owned enterprises, the Sultanates …


Title Ix And Gender Stereotype Theory: Protecting Students From Parental Status Discrimination, Jocelyn Tillisch Apr 2019

Title Ix And Gender Stereotype Theory: Protecting Students From Parental Status Discrimination, Jocelyn Tillisch

Seattle University Law Review

This Comment asserts that students who experience discrimination on the basis of parental status have a cause of action under Title IX by using the gender stereotyping theory that is common in Title VII analysis as illustrated by Tingley-Kelley v. Trustees of the University of Pennsylvania. Part I will first provide an overview of the applicable law surrounding Title IX and Title VII. Part II will briefly summarize application of the gender stereotype theory and the applicable case law that provides the legal framework for this proposition. Part III will detail how the Title VII framework can be followed to …


Indigenous Environmental Network V. United States Department Of State, Seth Sivinski Apr 2019

Indigenous Environmental Network V. United States Department Of State, Seth Sivinski

Public Land & Resources Law Review

Pipelines are an extremely efficient way to move large amounts of oil and gas across long distances. However, pipelines have become a lightning rod for environmentalists opposing the lines’ construction and the energy sector which considers the lines a must to achieve energy independence and security. Pipelines are massive projects often crossing interstate and international boundaries. As a result, they are subject to an extensive amount of government regulation with an accompanying assortment of legal challenges. Indigenous Environmental Network v. United States Department of State is the latest case in the Keystone XL pipeline saga, wherein the United States District …


Kloker V. Fort Peck Tribes, Hallee Kansman Apr 2019

Kloker V. Fort Peck Tribes, Hallee Kansman

Public Land & Resources Law Review

Kloker v. Fort Peck Tribes investigates and deciphers the application of the Indian canons of construction to the congressional formation and establishment of the Fort Peck reservation in Montana. In general, courts interpret congressional acts creating reservations through the lens of the tribal-federal government trust relationship. Although this case examines different substantive models of legal interpretation and theories of water law, the ultimate dispute is textual in nature—questioning the plain language of the establishment legislation itself.


Maralex Resources, Inc. V. Barnhardt, Bradley E. Tinker Apr 2019

Maralex Resources, Inc. V. Barnhardt, Bradley E. Tinker

Public Land & Resources Law Review

In Maralex Resources v. Barnhardt, Maralex and property owners brought an action to protect private property from BLM inspections of oil and gas lease sites. The Tenth Circuit looked at the plain meaning of a congressional statute and held in favor of Maralex, finding that BLM lacked authority to require a private landowner to provide BLM with a key to inspect wells of their property. The Tenth Circuit held BLM has the authority to conduct inspections without prior notice on private property lease sites; however, it is required to contact the property owner for permission before entering the property.


Murray V. Bej Minerals, Llc, Brett Berntsen Apr 2019

Murray V. Bej Minerals, Llc, Brett Berntsen

Public Land & Resources Law Review

Part of a dispute some 66 million years in the making, Murray v. BEJ Minerals, LLC considered for the first time whether dinosaur fossils—specifically a one-of-a-kind specimen containing entombed “dueling dinosaurs”—qualified as “minerals” for the purposes of a property transaction under Montana law. Finding no consistent statutory or dictionary definition for “mineral,” the Ninth Circuit relied on a test previously utilized by the Montana Supreme Court to hold that the dinosaur fossils constituted minerals due to their rare and exceptional qualities and were therefore part of the property’s mineral estate. The decision was promptly nullified, however, as the Ninth Circuit …


Hoopa Valley Tribe V. Ferc, Fredrick Aaron Rains Apr 2019

Hoopa Valley Tribe V. Ferc, Fredrick Aaron Rains

Public Land & Resources Law Review

In Hoopa Valley Tribe v. FERC, the Hoopa Valley Tribe challenged the intentional and continual delay of state water quality certification review of water discharged from a series of dams on the Klamath River in California and Oregon. The Federal Energy Regulatory Commission, the states of Oregon and California, and PacifiCorp, a hydroelectric operator, were implementing an administrative scheme designed to circumvent a one-year temporal requirement for review imposed on states by the Clean Water Act. This scheme allowed PacifiCorp to operate the series of dams for over a decade without proper state water quality certification. The United States …


Appeal No. 0966: Hardesty Production V. Division Of Oil & Gas Resources Management, Ohio Oil & Gas Commission Apr 2019

Appeal No. 0966: Hardesty Production V. Division Of Oil & Gas Resources Management, Ohio Oil & Gas Commission

Ohio Oil & Gas Commission Decisions

Review of Chief's Order 2018-242