Notice & Comment

Author: Aaron L. Nielson

Notice & Comment

Executive Order on Improving Customer Service (Plus This Week’s Plenary Session of the Administrative Conference)

Today, President Biden issued an Executive Order entitled Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government. I suspect that others will provide more substantive thoughts about the order’s various parts. Here, however, is the fact sheet if you want a summary and a list of the agencies involved. There is a lot […]

Notice & Comment

New to SSRN: Congress’s Anti-Removal Power

Last fall, in Collins v. Yellen, the U.S. Supreme Court invited me to brief and argue in defense of the constitutionality of the Federal Housing Finance Agency. By statute, the president can only fire the head of the FHFA “for cause.” The question in Collins was whether that provision unconstitutionally limits the president’s removal power. […]

Notice & Comment

The Logic of Collins v. Yellen

Today, President Biden fired the head of the Social Security Administration, despite the fact that Congress has declared that “[a]n individual serving in the office of Commissioner may be removed from office only pursuant to a finding by the President of neglect of duty or malfeasance in office.” The Office of Legal Counsel justified this […]