Administrative law is the biggest "fuck you" to the constitution. SCOTUS upholds 91% of ad law cases that come before it. DC Circuit is a bit more hostile toward ad law. Government agencies should not get a pass simply because they are government agencies. "Government knows best." I hope SCOTUS dismantles Auer and Seminole Rock in Kisor v. Wilkie (O'Rourke). Question one in the cert petition is:
"Whether the Court should overrule Auer and Seminole Rock."
Take it apart, Justices. Then it's on to Chevron.