Volume 63, Number 3

REPORT

Lobbying Law in the Spotlight: Challenges and Proposed Improvements

ARTICLES

An Inductive Understanding of Separation of Powers
Jack M. Beermann

An Empirical Study of Judicial Review of Agency Interpretations of Agency Rules
Richard J. Pierce, Jr. and Joshua Weiss

Rule by Reasonableness
David Zaring

COMMENTS

The Department of Veterans Affairs' Entitlement Complex: Attorney Fees and Administrative Offset After Astrue v. Ratliff
Stacy L.Z. Edwards

The Illusion of Interchangeability: The Benefits and Dangers of Guidance-Plus Rulemaking in the FDA's Biosimilar Approval Process
Jonathan Stroud

RECENT DEVELOPMENT

Fees From Mars: Why the FTC Needs to Regulate Mortgage Assistance Relief Services (MARS) Fees
Alexander Lutch