PHIL HAMBURGER, author of Is Administrative Law Unlawful? has an article up at SSRN: Deference to Administrative Interpretation: The Unasked Questions. The more attention I pay, the less impressed with deference to administrative agencies I become. He also has a post on it here.
InstaPundit is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.com.