Title
How Should We Judge Agencies’ Decisions “Not to Decide?”
Document Type
Online Essay
Publication Date
5-1-2014
Keywords
Process, Administrative Procedure, Adrian Vermeule, Cass Sunstein, OIRA, Regulatory Reform
Recommended Citation
Hobbs, James, "How Should We Judge Agencies’ Decisions “Not to Decide?”" (2014). The Regulatory Review - Analysis. 492.
https://scholarship.law.upenn.edu/regreview-analysis/492
COinS
Description
Working paper says agencies have broad, but cabined, discretion to delay and defer.