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The Interpretive Dimension of Seminole Rock
(George Mason Law Review, 2015)
A lively debate has emerged over the deferential standard of review courts apply when reviewing an agency’s interpretation of its own regulations. That standard, traditionally associated with Bowles v. Seminole Rock & Sand ...
Interpreting Regulations
(Michigan Law Review, 2012)
The age of statutes has given way to an era of regulations, but our jurisprudence has fallen behind. Despite the centrality of regulations to law, courts have no intelligible approach to regulatory interpretation. The ...