Ann R. Klee

Rebuilding Accountability in the Administrative State

When it comes to rulemaking, “It should no longer be sufficient for agency decision makers to assume that the only hurdle they have to meet is simply not being ‘clearly wrong.'”

Putting Foxes in Charge of Guarding Henhouses

“Chevron deference has created a regulatory landscape where agencies may in some cases do what they want, rather than what the law requires or allows them to do.”

Chevron’s Lack of Statutory Support

“If you had to distill the Chevron doctrine to nine words, I do not think you could do better than: ‘When I am confused, I go with the agency.'”

Chevron Undermines Checks and Balances

It is time to reconsider the extent to which we apply Chevron.

Is it Time to Reconsider Chevron Deference?

The Regulatory Review proudly features the remarks of Ann R. Klee, keynote speaker at the Penn Program on Regulation’s annual dinner.