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Article
Once More unto the Breach, Dear Friends - Levin on the Guidance Exception
Faculty Online Publications
  • Michael E. Herz, Benjamin N. Cardozo School of Law
Abstract

The late, great Kenneth Culp Davis was known for many things, but humility was not among them. He knew the answers; he knew them better than did the Supreme Court; and he knew that he knew them. So it is remarkable that there was a problem in administrative law he found “baffling.” That was the distinction between legislative rules, interpretive rules, and statements of policy.

Document Type
Article
Publication Date
4-16-2018
Publisher
Jotwell: The Journal of Things We Like (Lots)
Disciplines
Citation Information
Michael E. Herz. "Once More unto the Breach, Dear Friends - Levin on the Guidance Exception" (2018)
Available at: http://works.bepress.com/michael-herz/110/