Tom Merrill is clearly a well versed, knowledgeable, and experienced Columbia Law Professor and a great source on Administrative Law. Thanks for the link!
These federal agencies have come along way since the 1st one (the ICC) was created and seem to absolutely untouchably dominate the lives of Americans and their businesses and are in essence mini governments with all the indicia and virtually unrestrained legislative, judicial, and executive powers delegated to them.
Personally, do you believe that this is what the founding fathers had in mind?
Aren't more guardrails required by the courts if the SCOTUS is indeed moving towards a Unitary Executive?
What we are witnessing 1st hand (for the last 4 or 5 POTUS'S at least) is a disturbing trend, when the POTUS can't get what he wants from the US Congress he simply has one of his 100's of federal agencies find an obscure and/or sometimes broad statutory sentence and interpret it to fit his latest agenda. The student loan forgiveness case is just the latest example.
Maybe or maybe not the SCOTUS will address this next week during oral arguments in the student loan cases and eventually provide more clear cut rules for the MQD.