Meet Me in the Middle: The Search for the Appropriate Standard of Review for the APA's Good Cause Exception

Author:Kelli M. Golinghorst
Position:J.D. Candidate, The University of Iowa College of Law, 2018; B.A., Political Science and Economics, Luther College, 2014

Section 553 of the Administrative Procedure Act ("APA") governs informal agency rulemaking and requires agencies to proceed through what is known as "notice-and-comment" rulemaking. The good cause exception to these proceedings allows agencies to bypass notice-and-comment rulemaking and immediately promulgate a rule if the agency has good cause to do so. The appropriate standard of review for an... (see full summary)

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