Michael P. DeGrandis is Senior Litigation Counsel at the New Civil Liberties Alliance, a nonprofit civil rights organization that filed 21 petitions for rulemaking in federal agencies over the last 15 months, asking agencies to eliminate the unconstitutional practice of issuing and enforcing substantive guidance.
Trump's New Executive Orders To Restrain the Administrative State
Federal agencies evade the rulemaking process, yet still levy fines, revoke permits, and seize property via “guidance.” Trump’s orders may put a stop to this practice.
