Crowell & Moring

Earlier this week, the Supreme Court heard arguments in a case that could determine whether federal regulators may revise established interpretations of rules without first complying with the notice-and-comment rulemaking process required by the Administrative Procedure Act. Although the specific case before the Court (Perez v. MBA) involves a Department of Labor rule, a decision in this case could have a much broader impact on other agencies’ ability to change existing interpretations of rules in regulated industries including, for example, health care and energy. For additional information about the case and analysis of its impact, see the article authored by Crowell & Moring attorneys here.