Administrative Law Essays

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We especially thank and applaud Professor Lee for her innovative and insightful teaching of Administrative Law.* * *The Importance of Public Comments in Agency Rulemaking Decisions Mary Felder How do federal agencies balance state efficiency concerns with providing benefits for vulnerable citizens?

After advocates for low-income Americans pointed out deficiencies in the federal program that provides food support to those in need of assistance, the Food and Nutrition Service (FNS) attempted to restructure its benefits program to improve access to beneficiaries with disabilities or drug addiction who are living in treatment centers.

In recognition of the significant historical, cultural, and spiritual connections between tribes and park lands, the National Park Service (NPS) issued a final rule allowing federally-recognized tribes to apply for approval to gather and remove plants used for traditional purposes.

The NPS’s effort at continuing historical religious practices may undermine their sacredness, however, as the documentation of tribal practices needed to secure an approval is inconsistent with tribal oral traditions and secrecy around spiritual sites.

In the meantime, however, SNAP benefits of facility residents are no longer protected when they leave after the 16th of the month and residents lack institutional assistance with taking the steps needed to ensure they continue receiving their benefits.* * *Reviewing Tribes’ Traditional Claims to Plants in National Parks Asal Yunusov Gathering and removing plants from any national park in the United States is prohibited without express authorization under a federal statute or treaty.

This prohibition keeps many Native American tribes from performing cultural traditions rooted in harvesting and gathering resources in areas that are part of a national park.

Their essays appear below, in alphabetical order by each author’s last name.

We extend to Mary and Asal our sincerest congratulations—as we also congratulate and thank all the students whose excellent essays we read.

Because SNAP-eligible residents in facilities can be blind, disabled, or coping with addiction, CLS noted that they are particularly vulnerable and may not be capable of navigating SNAP requirements alone.

CLS recommended that the regulation require facilities to submit a change form on behalf of the resident and give that resident any information required to continue receiving SNAP.


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