Gwen and Marc open this episode with a deceptively simple babysitter analogy: you tell the sitter “use anything in the kitchen,” but you don’t expect her to mount a cutting board to the wall and teach knife-throwing, or install a $6,000 closet system. The permission technically covers those choices — but that’s clearly not what you meant. That disconnect becomes the doorway into the Major Questions Doctrine, the Court’s newest tool for saying: “If Congress meant to authorize something this big, it would’ve said so clearly.”
From there, they rewind to Brown & Williamson, when the FDA tried to regulate tobacco by treating nicotine like any other drug. The statutory text fit — in some ways perfectly — yet the Court refused to believe Congress hid such massive economic and political authority inside ordinary words. Gwen shows how that early instinct, even without a label, planted the seeds of today’s doctrine.
Then the episode turns to the decision that christened the doctrine by name: West Virginia v. EPA. Roberts framed the Clean Power Plan not as routine emissions regulation, but as a wholesale restructuring of the American energy sector — far too consequential, he argued, for an agency to find tucked inside an older statute. Through the Court’s own language, Gwen and Marc unpack what counts as a “major question”: billions in economic impact, deep political salience, dramatic expansions of authority, and situations where Congress has repeatedly considered but rejected similar proposals.
But they also highlight the doctrine’s shadows. The Court has never articulated a clear test; agencies don’t know how many “factors” are enough; and the dividing line between ordinary policymaking and “major” policymaking keeps shifting, depending on who’s drawing it.
Takeaway: Sometimes the words of a statute technically fit — but the Court refuses to believe Congress granted vast power by implication. When the decision is big enough, the Court demands clarity Congress rarely provides.
00:00:14 --> 00:00:17 Hello, and welcome to Administrative Remedies,
00:00:17 --> 00:00:19 because you can't fix what you don't understand.
00:00:19 --> 00:00:21 Brought to you in part by the University of Tulsa
00:00:21 --> 00:00:24 College of Law. I'm Gwendolyn Savitz, an associate
00:00:24 --> 00:00:26 professor here at TU and the associate dean of
00:00:26 --> 00:00:28 research and intellectual life. And I'm Mark
00:00:28 --> 00:00:31 Rourke. I'm the dean of the College of Law. We'll
00:00:31 --> 00:00:33 be breaking down complex doctrines with real
00:00:33 --> 00:00:35 -life analogies and examples to demystify the
00:00:35 --> 00:00:37 world of administrative law for everyone trying
00:00:37 --> 00:00:39 to understand how government actually works.
00:00:40 --> 00:00:41 Agencies are the main way the federal government
00:00:41 --> 00:00:44 gets things done. It's not through Congress for
00:00:44 --> 00:00:46 reasons we'll be addressing over the course of
00:00:46 --> 00:00:49 this series. All right. So, Mark, let's say you're
00:00:49 --> 00:00:50 going out for the night. You've left the kids
00:00:50 --> 00:00:53 with the babysitter and you said something like,
00:00:53 --> 00:00:55 feel free to use anything in the kitchen. What
00:00:55 --> 00:00:58 would you have meant? I mean, like stuff in the
00:00:58 --> 00:01:02 refrigerator, the microwave, the oven, maybe
00:01:02 --> 00:01:06 a blender if they're making cookies. So you'd
00:01:06 --> 00:01:08 be surprised if you came home and saw that she
00:01:08 --> 00:01:10 mounted a cutting board to the wall and was teaching
00:01:10 --> 00:01:13 your kids knife throwing. I mean. I'd be impressed,
00:01:13 --> 00:01:15 actually, especially if they got more accurate
00:01:15 --> 00:01:18 with their knife throwing. But what if they got
00:01:18 --> 00:01:20 less accurate with their knife throwing? That
00:01:20 --> 00:01:22 would be a problem. It would be a little scary,
00:01:22 --> 00:01:25 actually. Or what if you told her to keep the
00:01:25 --> 00:01:28 house tidy and came home to find that she had
00:01:28 --> 00:01:31 purchased and installed a $6 organizing
00:01:31 --> 00:01:35 system in one of the kids' closets? Well, if
00:01:35 --> 00:01:37 I'm being fair, their closets are really messy.
00:01:38 --> 00:01:42 But it depends on if I'm paying for it. Oh, yes,
00:01:42 --> 00:01:44 you are. If I'm paying for, oh, I would be absolutely
00:01:44 --> 00:01:47 livid. That would be very upsetting. Sometimes
00:01:47 --> 00:01:49 the literal words of the directions that someone
00:01:49 --> 00:01:52 was given or the permission that someone was
00:01:52 --> 00:01:55 given can cover something, even though it really,
00:01:55 --> 00:01:59 really wasn't what you meant. Today, we are talking
00:01:59 --> 00:02:01 about the major question of doctrine, and that
00:02:01 --> 00:02:04 is essentially the court saying, yes, the statute's
00:02:04 --> 00:02:07 words could technically cover that. But if Congress
00:02:07 --> 00:02:09 meant to let you do it, they would have been
00:02:09 --> 00:02:14 a lot clearer. So let's talk about how this played.
00:02:14 --> 00:02:22 So we are going back to 1996. So just a question.
00:02:22 --> 00:02:26 Did the idea about major questions exist before
00:02:26 --> 00:02:30 the name? Very much so. This is before the major
00:02:30 --> 00:02:33 questions doctrine was called the major questions
00:02:33 --> 00:02:35 doctrine. But I think this is the clearest way
00:02:35 --> 00:02:38 to think about how it began. We're talking about
00:02:38 --> 00:02:41 FDA v. Brown and Williamson. In this case, FDA
00:02:41 --> 00:02:44 looked at its statute, the Food, Drug, and Cosmetic
00:02:44 --> 00:02:47 Act, and said nicotine is a drug, cigarettes
00:02:47 --> 00:02:49 are drug delivery devices. We have authority
00:02:49 --> 00:02:52 over those, so we can regulate tobacco. That
00:02:52 --> 00:02:55 sounds logical. It's definitely a fair reading
00:02:55 --> 00:02:57 of the statute. Look at the definition of a drug.
00:02:58 --> 00:03:01 The term drug means articles, other than food,
00:03:01 --> 00:03:04 intended to affect the structure or any function
00:03:04 --> 00:03:06 of the body. Under that, is nicotine a drug?
00:03:06 --> 00:03:09 Absolutely. It's addictive. It changes brain
00:03:09 --> 00:03:13 chemistry. Just like an asthma inhaler or an
00:03:13 --> 00:03:15 insulin injector is a device that delivers drugs
00:03:15 --> 00:03:18 to the body, cigarettes deliver nicotine. So
00:03:18 --> 00:03:21 case closed. FDA can regulate them, right? I'm
00:03:21 --> 00:03:24 guessing where you're going is that they can't.
00:03:24 --> 00:03:26 The tobacco company sued and the Supreme Court
00:03:26 --> 00:03:29 said no. Justice O 'Connor said we are confident
00:03:29 --> 00:03:32 that Congress could not have intended to delegate
00:03:32 --> 00:03:35 a decision of such economic and political significance
00:03:35 --> 00:03:39 to an agency in so cryptic a fashion. To find
00:03:39 --> 00:03:42 that the FDA has the authority to regulate tobacco
00:03:42 --> 00:03:45 products, one must not only adopt an extremely
00:03:45 --> 00:03:48 strained understanding of safety. as is used
00:03:48 --> 00:03:50 throughout the act, a concept central to the
00:03:50 --> 00:03:54 FDCA's regulation scheme, but also ignore the
00:03:54 --> 00:03:57 plain implication of Congress's subsequent tobacco
00:03:57 --> 00:04:00 -specific legislation. She's essentially explaining
00:04:00 --> 00:04:02 the logic of the doctrine there. She's not naming
00:04:02 --> 00:04:04 it, but the seed is planted. If this is some
00:04:04 --> 00:04:07 sort of huge economic decision, you're going
00:04:07 --> 00:04:09 to need clear congressional permission. So then
00:04:09 --> 00:04:11 when did they actually name the major questions
00:04:11 --> 00:04:14 doctrine? That wasn't until 2022. This is really
00:04:14 --> 00:04:18 new. This was in West Virginia v. EPA, and it's
00:04:18 --> 00:04:20 the first time they're explicitly using the label,
00:04:20 --> 00:04:23 although there had been cases that hinted at
00:04:23 --> 00:04:26 it on the shadow docket earlier. This is a climate
00:04:26 --> 00:04:31 change case. Yes. In 2015, Obama's EPA issues
00:04:31 --> 00:04:33 the Clean Power Plan. It's supposed to reduce
00:04:33 --> 00:04:36 CO2 from power plants, but they didn't just require
00:04:36 --> 00:04:39 better technology at each plant. They required
00:04:39 --> 00:04:41 generation shifting, pushing the entire grid
00:04:41 --> 00:04:45 to move from coal towards natural gas. And renewables.
00:04:46 --> 00:04:50 So that sounds pretty massive. It was. Here,
00:04:50 --> 00:04:53 read what the plan actually required. So it says
00:04:53 --> 00:04:55 the best system for emissions reductions for
00:04:55 --> 00:04:58 existing plants included three types of measures
00:04:58 --> 00:05:00 which the agency called building blocks. The
00:05:00 --> 00:05:02 first building block was heat rate improvements
00:05:02 --> 00:05:06 at coal -fired plants, essentially practices
00:05:06 --> 00:05:08 such plants could undertake to burn coal more
00:05:08 --> 00:05:11 efficiently. But such improvements, EPA stated,
00:05:12 --> 00:05:14 would lead only to small emission reductions
00:05:14 --> 00:05:17 because coal -fired power plants were already
00:05:17 --> 00:05:21 operating near optimum efficiency. On the agency's
00:05:21 --> 00:05:23 view, much larger emission reductions were needed
00:05:23 --> 00:05:27 from coal -fired plants to address climate change.
00:05:27 --> 00:05:29 So the agency included two additional building
00:05:29 --> 00:05:32 blocks in its BSER, both of which involve what
00:05:32 --> 00:05:35 are called generation shifting from higher emitting
00:05:35 --> 00:05:38 to lower emitting producers of electricity. It's
00:05:38 --> 00:05:42 pretty dense. But what she's saying is the EPA
00:05:42 --> 00:05:45 is functionally restructuring the entire American
00:05:45 --> 00:05:49 electricity sector. However, this rule never
00:05:49 --> 00:05:51 took effect. Trump came into office and repealed
00:05:51 --> 00:05:54 it. Then Biden's EPA was considering something
00:05:54 --> 00:05:56 similar when the Supreme Court decided to step
00:05:56 --> 00:06:00 in. So the court reviewed a dead rule. They did,
00:06:00 --> 00:06:03 which alone upset a lot of people. The court
00:06:03 --> 00:06:07 wanted to settle the question and. refused to
00:06:07 --> 00:06:10 let the case drop when it was no longer a live
00:06:10 --> 00:06:14 dispute. Aren't there abstention doctrines that
00:06:14 --> 00:06:16 prevent the court from considering those kinds
00:06:16 --> 00:06:19 of cases? There certainly should have been. This
00:06:19 --> 00:06:22 case was moot, but they forged ahead nevertheless.
00:06:23 --> 00:06:27 So when Justice Roberts... used this opinion
00:06:27 --> 00:06:29 to crystallize the major questions doctrine.
00:06:29 --> 00:06:33 He wrote, in certain extraordinary cases, both
00:06:33 --> 00:06:35 separation of powers principles and practical
00:06:35 --> 00:06:38 understanding of legislative intent make us reluctant
00:06:38 --> 00:06:41 to read into ambiguous statutory texts the delegation
00:06:41 --> 00:06:44 claimed to be lurking there. To convince us otherwise,
00:06:44 --> 00:06:46 something more than a merely plausible textual
00:06:46 --> 00:06:50 basis for the agency action is necessary. The
00:06:50 --> 00:06:52 agency instead must point to clear congressional
00:06:52 --> 00:06:56 authorization for the power it claims. Importantly,
00:06:56 --> 00:06:59 he also used the name. Our precedent counsel's
00:06:59 --> 00:07:03 skepticism toward EPA's claim that Section 111
00:07:03 --> 00:07:07 empowers it to devise carbon emission caps based
00:07:07 --> 00:07:10 on a generation -shifting approach. To overcome
00:07:10 --> 00:07:13 that skepticism, the government must, under the
00:07:13 --> 00:07:16 major questions doctrine, point to a clear congressional
00:07:16 --> 00:07:19 authorization to regulate in that manner. All
00:07:19 --> 00:07:22 the government can offer, however, is the agency's
00:07:22 --> 00:07:24 authority to establish emissions gaps at a level
00:07:24 --> 00:07:26 reflecting the application of the best system
00:07:26 --> 00:07:30 of emission reduction adequately demonstrated.
00:07:31 --> 00:07:34 At this point, EPA is saying we need to establish
00:07:34 --> 00:07:36 the best system of emissions reductions for CO2
00:07:36 --> 00:07:39 in general, which they had been explicitly ordered
00:07:39 --> 00:07:41 to do by the Supreme Court in Massachusetts EPA.
00:07:42 --> 00:07:45 And the best way we can do that is moving away
00:07:45 --> 00:07:48 from coal power plants. Per unit of heat, coal
00:07:48 --> 00:07:50 is a lot less efficient than natural gas. So
00:07:50 --> 00:07:53 it is not the most efficient way to generate
00:07:53 --> 00:07:57 heat to create electricity. But the court had
00:07:57 --> 00:08:00 major issues with this interpretation. Even if
00:08:00 --> 00:08:03 the text technically fits, like nicotine is a
00:08:03 --> 00:08:05 drug, it's not enough for transformative powers
00:08:05 --> 00:08:08 like this. So Brown and Williamson was the birth,
00:08:08 --> 00:08:12 but West Virginia was the baptism. Yes. Now it
00:08:12 --> 00:08:17 has a name. Well, OK. So how do we know what
00:08:17 --> 00:08:19 counts as a major question? What exactly is that
00:08:19 --> 00:08:23 test? That is a crucial question, which nobody
00:08:23 --> 00:08:25 can really say for sure. The court has talked
00:08:25 --> 00:08:27 about several factors to consider, although they
00:08:27 --> 00:08:30 haven't given a clear test yet. Let's break down
00:08:30 --> 00:08:32 some of the main factors in both of the cases
00:08:32 --> 00:08:36 we just talked about. Okay. The first factor,
00:08:36 --> 00:08:38 economic significance. In Brown and Williamson,
00:08:38 --> 00:08:41 the economic impact of the tobacco industry.
00:08:41 --> 00:08:44 It was massive, hundreds of billions of dollars.
00:08:45 --> 00:08:47 Yes. So if we have some sort of economic impact
00:08:47 --> 00:08:50 in the billions, that's a major question. Now
00:08:50 --> 00:08:53 let's look at West Virginia v. EPA and see what
00:08:53 --> 00:08:55 Roberts had to say about the economic impact
00:08:55 --> 00:08:58 there. EPA's own modeling concluded that the
00:08:58 --> 00:09:00 rule would entail billions of dollars in compliance
00:09:00 --> 00:09:03 costs, raise electricity prices in every state,
00:09:03 --> 00:09:06 and eliminate tens of thousands of jobs across
00:09:06 --> 00:09:09 various sectors. So both of these cases involve
00:09:09 --> 00:09:12 billions of dollars in fundamental economic restructuring.
00:09:12 --> 00:09:14 But it's not just about money. The next issue
00:09:14 --> 00:09:18 is... Is there political significance? Does the
00:09:18 --> 00:09:20 issue generate significant political controversy?
00:09:20 --> 00:09:24 Okay. Tobacco regulation has always been politically
00:09:24 --> 00:09:27 explosive, and climate change is one of the most
00:09:27 --> 00:09:29 politically divisive issues of our time. When
00:09:29 --> 00:09:32 an agency wades into some sort of political charge
00:09:32 --> 00:09:36 territory, like in these cases, using statutory
00:09:36 --> 00:09:38 language that wasn't just enacted to allow the
00:09:38 --> 00:09:41 agency to do that, that's another reason the
00:09:41 --> 00:09:42 court can determine it's a major question doctrine.
00:09:43 --> 00:09:46 The next factor is what the court's calling regulatory
00:09:46 --> 00:09:49 significance, where this dramatically expands
00:09:49 --> 00:09:51 the agency's authority. So in Bryan Williamson,
00:09:51 --> 00:09:55 FDA had existed since 1906 and had never tried
00:09:55 --> 00:09:58 to claim authority over tobacco, but it suddenly
00:09:58 --> 00:10:00 claimed to discover this power after 90 years.
00:10:00 --> 00:10:03 That was suspicious. And in West Virginia, Roberts
00:10:03 --> 00:10:05 made the same point about the EPA. Here's what
00:10:05 --> 00:10:09 he said. Prior to 2015, the EPA had always set
00:10:09 --> 00:10:11 emissions limits under Section 111 based on the
00:10:11 --> 00:10:14 application of measures that would reduce pollution
00:10:14 --> 00:10:16 by causing the regulated source to operate more
00:10:16 --> 00:10:19 cleanly. It had never devised a cap by looking
00:10:19 --> 00:10:22 into a system that would reduce pollution simply
00:10:22 --> 00:10:25 by shifting polluting activity from dirtier to
00:10:25 --> 00:10:29 cleaner sources. Both agencies were trying to
00:10:29 --> 00:10:32 claim new powers based on old statutes. But it's
00:10:32 --> 00:10:34 important to note that in West Virginia, the
00:10:34 --> 00:10:37 court said it was absolutely fine for EPA to
00:10:37 --> 00:10:40 tell power plants that they needed to burn coal
00:10:40 --> 00:10:43 more cleanly themselves. That was sort of stage
00:10:43 --> 00:10:46 one of that three -step process. That part was
00:10:46 --> 00:10:48 fine. That's what they've been doing for decades.
00:10:48 --> 00:10:51 They just couldn't make the coal plants pay for
00:10:51 --> 00:10:54 other types of energy. OK, so we have costs.
00:10:54 --> 00:10:57 We have political significance. We have regulatory
00:10:57 --> 00:11:01 significance. Is there anything else? Yes. Another
00:11:01 --> 00:11:05 issue. Has Congress considered and rejected giving
00:11:05 --> 00:11:07 the agency this specific authority? Here's what
00:11:07 --> 00:11:09 they said about that in Brown and Williamson.
00:11:09 --> 00:11:12 Congress has directly spoken to the question
00:11:12 --> 00:11:15 issue and precluded the FDA from regulating tobacco
00:11:15 --> 00:11:19 products. Congress has created a distinct regulatory
00:11:19 --> 00:11:22 scheme for tobacco and squarely rejected proposals
00:11:22 --> 00:11:25 to give the FDA authority over tobacco. She's
00:11:25 --> 00:11:27 saying Congress had literally voted down bills
00:11:27 --> 00:11:30 to allow the FDA to do this. And West Virginia,
00:11:30 --> 00:11:33 Robert said something similar. Finally, we cannot
00:11:33 --> 00:11:36 ignore that the regulatory writ EPA newly uncovered
00:11:36 --> 00:11:40 conveniently enabled it to enact a program that
00:11:40 --> 00:11:42 long after the dangers posed by greenhouse gas
00:11:42 --> 00:11:45 emissions had become well -known, Congress considered
00:11:45 --> 00:11:49 and rejected multiple times. At bottom, the Clean
00:11:49 --> 00:11:51 Power Plan essentially adopted a cap -and -trade
00:11:51 --> 00:11:54 scheme or set of state cap -and -trade schemes
00:11:54 --> 00:11:56 for carbon. Congress, however, has consistently
00:11:56 --> 00:11:59 rejected proposals to amend the Clean Air Act
00:11:59 --> 00:12:02 to create such a program. So if Congress has
00:12:02 --> 00:12:05 looked at this exact question and said, no, that's
00:12:05 --> 00:12:08 a strong signal, That's a major question. Yes.
00:12:08 --> 00:12:11 There's also another factor that's clear in West
00:12:11 --> 00:12:14 Virginia. Does the agency's interpretation involve
00:12:14 --> 00:12:17 some sort of fundamental policy question that
00:12:17 --> 00:12:20 the court thinks Congress should address? So,
00:12:20 --> 00:12:23 like, some decisions are just too important for
00:12:23 --> 00:12:26 society for us to leave to courts. We expect
00:12:26 --> 00:12:29 our elected representatives, not agencies, to
00:12:29 --> 00:12:32 make them, like restructuring the entire energy
00:12:32 --> 00:12:35 sector. Yes. So Robert said EPA was essentially
00:12:35 --> 00:12:38 choosing America's energy future. And that's
00:12:38 --> 00:12:39 the kind of thing that Congress should be doing,
00:12:39 --> 00:12:42 not agency bureaucrats interpreting vague statutory
00:12:42 --> 00:12:45 language. OK. So to summarize these factors,
00:12:46 --> 00:12:48 billions in economic impact, political controversy,
00:12:48 --> 00:12:52 novel use of old authority, Congress having considered
00:12:52 --> 00:12:54 and rejected it, and fundamental policy questions.
00:12:54 --> 00:12:57 Right. Those are the big ones. And you can see
00:12:57 --> 00:13:00 how both of these cases, at least arguably, hit
00:13:00 --> 00:13:03 all of them. There is a question, however, if
00:13:03 --> 00:13:06 a case doesn't hit all of them. Is two of these
00:13:06 --> 00:13:08 factors enough? Is three? The court hasn't said.
00:13:09 --> 00:13:12 Well, that seems problematic. It is really problematic
00:13:12 --> 00:13:14 because this means that agencies won't know in
00:13:14 --> 00:13:17 advance where the line is. And that's also because
00:13:17 --> 00:13:19 there are really two versions of the major questions
00:13:19 --> 00:13:23 doctrine. So two flavors of the major questions
00:13:23 --> 00:13:26 doctrine. I'm assuming that there are flavors
00:13:26 --> 00:13:29 that are more favorable to agencies and flavors
00:13:29 --> 00:13:32 that are less favorable to the agencies. Yes,
00:13:32 --> 00:13:35 you could say that. So the first version we're
00:13:35 --> 00:13:38 going to call the weak version. This says if
00:13:38 --> 00:13:41 an agency is claiming power over a major question,
00:13:41 --> 00:13:43 courts should be skeptical. They should interpret
00:13:43 --> 00:13:45 the statute narrowly and not assume that Congress
00:13:45 --> 00:13:47 meant to delegate significant authority unless
00:13:47 --> 00:13:50 the statute clearly says so. So it's about how
00:13:50 --> 00:13:52 the courts read the statute. Yes, it's just an
00:13:52 --> 00:13:55 interpretive tool. The strong version is a lot
00:13:55 --> 00:13:58 more aggressive. It says that if something qualifies
00:13:58 --> 00:14:01 as a major question, ordinary statutory authorization
00:14:01 --> 00:14:04 isn't enough. Congress has to provide extraordinarily
00:14:04 --> 00:14:08 clear statutory authorization, like a clear statement
00:14:08 --> 00:14:12 rule. So even if the statute unambiguously seems
00:14:12 --> 00:14:14 broad enough to cover this, the courts would
00:14:14 --> 00:14:17 require Congress to speak with increased clarity,
00:14:17 --> 00:14:20 extraordinary clarity, one might say. We think
00:14:20 --> 00:14:23 of this in terms of the babysitter. You tell
00:14:23 --> 00:14:25 the babysitter, make sure the kids are safe.
00:14:25 --> 00:14:28 Under the weak version, she can't build a fence
00:14:28 --> 00:14:30 around your entire yard. We're going to read
00:14:30 --> 00:14:32 the instructions narrowly. It means keep an eye
00:14:32 --> 00:14:35 on them. Don't let them play with knives. But
00:14:35 --> 00:14:38 even though building a fence could help keep
00:14:38 --> 00:14:40 them safe, because it's questionable whether
00:14:40 --> 00:14:42 that's what you meant, they would assume you
00:14:42 --> 00:14:45 didn't. But under the strong version, even if
00:14:45 --> 00:14:47 you said, do whatever you think is necessary
00:14:47 --> 00:14:50 to keep them safe, she still can't install the
00:14:50 --> 00:14:53 fence unless you say so explicitly. Because this
00:14:53 --> 00:14:55 would be such a major decision, one you'd expect
00:14:55 --> 00:14:58 the parents to make. So the strong version says,
00:14:58 --> 00:15:01 don't just look at the text. Ask whether Congress
00:15:01 --> 00:15:04 would really hide a huge power inside the ordinary
00:15:04 --> 00:15:08 words it used. Yes. And that's the version we're
00:15:08 --> 00:15:12 going to be talking about next time. So next
00:15:12 --> 00:15:14 time on Administrative Remedies, we will pick
00:15:14 --> 00:15:17 up where this stopped and continue our exploration
00:15:17 --> 00:15:20 of the major questions doctrine. So that does
00:15:20 --> 00:15:21 it for today's episode on administrative remedies.
00:15:21 --> 00:15:24 Thank you for joining us today. Please, if you
00:15:24 --> 00:15:27 enjoy this podcast and enjoy this episode, give
00:15:27 --> 00:15:31 us a like on Spotify, iTunes, or whatever platform
00:15:31 --> 00:15:33 you're listening on. And be sure to tune in next
00:15:33 --> 00:15:36 time where we'll continue to dive into the contours
00:15:36 --> 00:15:38 of administrative law. Because remember, you
00:15:38 --> 00:15:39 can't fix what you don't understand.