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
Administrative Law
Recommended Citation
Herz, Michael E., "Once More unto the Breach, Dear Friends - Levin on the Guidance Exception" (2018). Online Publications. 45.
https://larc.cardozo.yu.edu/faculty-online-pubs/45
