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"Statutory NonDelegation": Learning from Florida's Recent Experience in Administrative Procedure Reform
(Widener Journal of Public Law, 1999)
In this Article, I assess one of the more notable reforms Florida made to its APA in 1996 with the intention of enhancing the accountability of agency rulemaking, and I discuss the lessons other state reformers can learn ...
Beyond Accountability: Arbitrariness and Legitimacy in the Administrative State
(New York University Law Review, 2003)
This Article argues that efforts to square the administrative state with the constitutional
structure have become too fixated on the concern for political accountability. As a result, those efforts have overlooked an ...