Sidestepping Chevron: Reframing Agency Deference for an Era of Private Governance

AR Cooper - Geo. LJ, 2010 - HeinOnline
The traditional view of administrative regulation as heavy-handed, agencycentered
command-and-control is slowly but surely eroding, only to be replaced by the incoming tides …

Sidestepping Chevron: Reframing Agency Deference for an Era of Private Governance

A Cooper - Georgetown Law Journal, 2011 - papers.ssrn.com
Judicial interpretation of regulatory standards generally relies on the presumption that
agencies are politically accountable and democratically “appointed” actors. As a result …