Sebastian the Ibis
Member
Folks,
Tuesday Morning, the Supreme Court overturned the D.C. Circuits' Paralyzed Veterans Doctrine in Perez v. Mortgage Bankers Ass'n. The gist of the ruling is that notice and comment is no longer required for interpretive rule changes under the D.C. Circuit's interpretation of the Administrative Procedures Act.
I have not had a chance to dig into the Perez opinion in any detail, but I wonder if the ATF's action Tuesday regarding the notice and comment period for SS109 is really the ATF just digesting Perez and figuring out how to jamb it down our throats.
Are there any APA wonks on this board that might be able to shed some light this issue?
A link to the Perez opinion is here: http://www.supremecourt.gov/opinions/14pdf/13-1041_0861.pdf
Tuesday Morning, the Supreme Court overturned the D.C. Circuits' Paralyzed Veterans Doctrine in Perez v. Mortgage Bankers Ass'n. The gist of the ruling is that notice and comment is no longer required for interpretive rule changes under the D.C. Circuit's interpretation of the Administrative Procedures Act.
I have not had a chance to dig into the Perez opinion in any detail, but I wonder if the ATF's action Tuesday regarding the notice and comment period for SS109 is really the ATF just digesting Perez and figuring out how to jamb it down our throats.
Are there any APA wonks on this board that might be able to shed some light this issue?
A link to the Perez opinion is here: http://www.supremecourt.gov/opinions/14pdf/13-1041_0861.pdf