Regulation of Representatives in Agency Proceedings

This project explores how agencies regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative proceedings. It addresses, among other things, why different agencies adopt different rules governing representatives' conduct; the ways in which different agencies’ rules operate; how different rules, and inter-agency variation in those rules, affect agencies, representatives, and persons affected by agency actions; whether agencies should consider adopting rules on certain subjects and what those rules should provide; how agencies should formulate such rules; and where agencies should publish them. With respect to those subjects, the project seeks to identify best practices for agencies in developing and modifying their rules regulating representatives.


Staff Counsel
Committee Chair
Associate General Counsel for Marketing, Regulatory, and Food Safety Programs
U.S. Department of Agriculture
Committee Chair
Gibson Dunn & Crutcher LLP