Regulatory Comments and the Major Questions Doctrine
Process, Administrative Law, Deference to Agencies, Judicial deference, notice-and-comment rulemaking, Participation, Public Comment
Brunstein, Natasha and Revesz, Richard L., "Regulatory Comments and the Major Questions Doctrine" (2021). The Regulatory Review - Opinion. 125.
Courts should not rely on the number of public comments to assess the legality of regulations.