Connor N. Raso

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Strategic or Sincere? Analyzing Agency Use of Guidance Documents

119 Yale L.J. 782 (2010).  This Note examines whether U.S. regulatory agencies frequently use guidance documents to issue policy decisions, avoiding the notice and comment process and other procedures normally required to issue rules. Legal scholars and recent presidential administrations both have debated this issue. This Note uses newly available data to conduct the first large-scale analysis of whether agencies...