D.C. Circuit Review—Reviewed: When Does a Rule Become a Rule?
The D.C. Circuit has once again addressed the surprisingly vexing question of when a rule becomes a rule. National Council of Agricultural Employers v. Department of Labor involves two competing rules modifying the H-2A farmworker visa program. The Trump administration’s Department of Labor submitted a final rule to the Office of the Federal Register (OFR) on January […]