The Truth of Erasure?

If you have been following the debate about universal or nationwide remedies, you know that a lot of attention is currently being paid to the Administrative Procedure Act and vacatur. One of the most recent articles on this question is The Truth of Erasure: Universal Remedies for Universal Agency Actions, by T. Elliot Gaiser, Mathura Sridharan, and Nicholas Cordova. I have just published an analysis and response at Notice & Comment, the blog of the Yale Journal of Regulation, and you can read it here.