Opinions – 1/17/13 – U.S. 4th Circuit Court of Appeals

Administrative Law Regulatory action as “rule making” BOTTOM LINE: The Department of Labor’s suspension of various regulations for temporary agricultural workers and reinstatement of prior regulations constituted “rule making” under Administrative Procedure Act, and by failing to provide meaningful opportunity for public comment, or to solicit or receive relevant comments regarding the regulations’ substance or merits, ...

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