Agency General Counsels, Beware
Federal agencies can face legal risk if they only provide constructive notice of regulatory changes through publication and FOIA “availability.”
Joshua Galperin is a professor of law at Pace Law School. He previously taught at the University of Pittsburgh School of Law and Yale Law School, where he directed the Environmental Protection Clinic.
Federal agencies can face legal risk if they only provide constructive notice of regulatory changes through publication and FOIA “availability.”