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Chris Walker

@chrisjwalker.bsky.social
5.6K followers 406 following 106 posts

Law Prof @ umich (formerly Ohio State), ABA AdLaw Section past chair, YaleJREG blogger, #adlaw nerd, dad of four michigan.law.umich.edu/faculty-and-…

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Chris Walker @chrisjwalker.bsky.social · 22/08/2026
New to SSRN -- Delegation and Independent Judgment: My draft contribution to a terrific Notre Dame Law Review symposium on Congress and the administrative state, in which I revisit Jonathan Adler and my 2020 article Delegation and Time: papers.ssrn.com/sol3/papers....
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Michigan Law @umichlaw.bsky.social · 23/07/2026
5 Questions with Professor @chrisjwalker.bsky.social about his new paper, Preserving Both Agency Expertise and Accountability in the Unitary Executive. 5Qs: michigan.law.umich.edu/news/5qs-wal... The paper on @ssrn.bsky.social: papers.ssrn.com/sol3/papers....
michigan.law.umich.edu
5Qs: Walker Makes a Conservative Argument for a Professionalized Civil Service | University of Michigan Law School
The US Supreme Court recently ruled in Trump v. Slaughter that the president has broad latitude to fire commissioners of most federal regulatory agencies. That decision has led to questions about what...
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Chris Walker @chrisjwalker.bsky.social · 28/05/2026
New to SSRN: I've posted a draft of a symposium essay, entitled Preserving Both Agency Expertise and Accountability in the Unitary Executive. In this essay, I make the conservative case for a professionalized civil service. Paper here: ssrn.com/abstract=684...
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Greg Shill @gregshill.com · 13/04/2026
This event—a ton of fun—was the Platonic ideal of scholarly exchange. Just wrapped up a meeting with my co-author to process all the feedback. We learned so much from the papers too. B1G thanks to @uwlawdemocracy.bsky.social, Alex, @chrisjwalker.bsky.social & commenters Nina & @nbagley.bsky.social!
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State Democracy Research Initiative @uwlawdemocracy.bsky.social · 13/04/2026
We had a lovely time in Ann Arbor at the University of Michigan Law School co-sponsoring an academic roundtable on state and local governance with Alexandra Klass, Nina Mendelson, and @chrisjwalker.bsky.social!!
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Chris Walker @chrisjwalker.bsky.social · 10/04/2026
New to SSRN: The George Washington Law Review invited me to pen the foreword to its annual administrative law issue. Here's a draft of that article, entitled Proportionality in Administrative Law: ssrn.com/abstract=655...
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Maria Ponomarenko @mariaponomarenko.bsky.social · 24/03/2026
TOMORROW: Excited to join @chrisjwalker.bsky.social and Margaret Kwoka for an @americanbar.org webinar to discuss our papers forthcoming in the GWLR's Annual Review of Administrative Law. Register here: www.americanbar.org/events-cle/m...
americanbar.org
Emerging Issues in Administrative Law
This panel will explore current and critical issues in administrative law, including government records, reorganization by past and current presidents, and the proportionality principle in administra…
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Chris Walker @chrisjwalker.bsky.social · 26/03/2026
New to SSRN: @Aaron_L_Nielson and I have posted a draft of our new paper, Article II and the Civil Service, which the Virginia Law Review will kindly be publishing. Plenty of time to incorporate feedback. Link here: papers.ssrn.com/sol3/papers....
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Brandon Johnson @bjeromy.bsky.social · 25/02/2026
My thanks to @chrisjwalker.bsky.social and the student editors of the Yale Journal on Regulation Notice and Comment blog for publishing this short discussion of Justice Thomas’s dangerously executive-empowering dissent in Learning Resources, Inc. v. Trump. www.yalejreg.com/nc/vesting-c...
yalejreg.com
Vesting Clause Asymmetry in Justice Thomas’s Learning Resources Dissent - Yale Journal on Regulation
The Supreme Court’s opinion in Learning Resources, Inc. v. Trump is sure to garner countless news reports, media commentaries, and academic responses. Much of this attention will focus on Chief Justic...
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Jed H. Shugerman @jedshug.bsky.social · 19/02/2026
I’m excited to participate in this symposium “Constitutional Checks and Balances Under Trump’s Second Term” on Friday! Our panel at 1:30: Humphrey’s & Appointment/Removal: @andreascoseriakatz.bsky.social @kexelchabot.bsky.social @chrisjwalker.bsky.social www.villanova.edu/university/l...
villanova.edu
The Villanova Law Review 2026 Norman J. Shachoy Symposium, 02/20 | Villanova University
This year’s Villanova Law Review Norman J. Shachoy Symposium features a series of discussions on constitutional checks and balances, focusing on how the modern executive branch shapes those checks.
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Chris Walker @chrisjwalker.bsky.social · 01/01/2026
Hot off the press! @nyulawreview.bsky.social Volume 100 symposium issue: Where Does Administrative Law Go From Here? Quick post linking to all of the terrific articles: www.yalejreg.com/nc/nyu-law-r...
yalejreg.com
NYU Law Review Volume 100 Symposium Issue: Where Does Administrative Law Go From Here? - Yale Journal on Regulation
In April 2025, the NYU Law Review and the Institute for Policy Integrity at NYU School of Law hosted a terrific symposium entitled Where Does Administrative Law Go from Here? Just before the new year,...
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Christina L. Boyd @theclboyd.bsky.social · 09/12/2025
My colleagues and I studied the effect on Obama nominees alone, pre- and post- Nov 2013. We find post-filibuster: faster confirmation times, higher confirmation rates, but not a big shift to appoint more liberal nominees (plotted here). www.degruyterbrill.com/document/doi...
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Christina L. Boyd @theclboyd.bsky.social · 09/12/2025
Definitely potential for a post-filibuster effect, but not enough presidencies per party yet to really see (e.g., for Rs, impossible to untangle filibuster end from a pure Trump effect).
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Michigan Law @umichlaw.bsky.social · 25/11/2025
It's that time of year again! #GoBlue
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Chris Walker @chrisjwalker.bsky.social · 25/11/2025
It's my fourth year teaching here at Michigan Law, and my fourth big game since moving to The School Up North. We love it here in Michigan, but our football loyalties remain unchanged. 🤓 Time to re-up my favorite welcome video: youtu.be/jWCFaJ0tMfE?...
youtu.be
The Game at Michigan Law
YouTube video by Michigan Law
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Chris Walker @chrisjwalker.bsky.social · 22/10/2025
On the Gray Matters podcast, Jace Lington and I had a great conversation about Congress, separation of powers, and the future of the administrative state. Details: www.yalejreg.com/nc/gray-cent...
yalejreg.com
Gray Center Podcast on Congress and the Shifting Sands in Administrative Law - Yale Journal on Regulation
A couple weeks ago I recorded a Gray Matters podcast with Jace Lington, which was a lot of fun. You can give it a listen here. The C. Boyden Gray Center is such a great resource in the field of admini...
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Chris Walker @chrisjwalker.bsky.social · 22/10/2025
Attn #adlaw law geeks: Registration is OPEN for Annual ABA Administrative Law Virtual Conference (11/20-11/21): www.yalejreg.com/nc/registrat... Terrific program this year. $25 for law students; Thursday 101 programming & Friday developments panels are a great way to do a deep #adlaw dive. 🤓
yalejreg.com
Registration is OPEN: Annual ABA Administrative Law Virtual Conference, November 20-21, 2025 - Yale Journal on Regulation
The November 20-21, 2025 Annual ABA Administrative Law Conference registration is now open!  Please see the conference brochure for more information and a registration form.  In view of current condit...
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Michigan Law @umichlaw.bsky.social · 22/10/2025
New from Professor @chrisjwalker.bsky.social in the Yale Journal on Regulation: "Centering Proportionality in the Administrative Procedure Act" www.yalejreg.com/nc/centering...
yalejreg.com
Centering Proportionality in the Administrative Procedure Act - Yale Journal on Regulation
This post is part of Notice & Comment’s symposium on the Senate Post-Chevron Working Group Report. For other posts in the series, click here. In this era of the rapid change in administrative law—both...
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Dan Deacon @dtdeacon.bsky.social · 06/10/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is "Remedies in the Officer Removal Cases," by Sam Bray. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Remedies in the Officer Removal Cases," by Samuel Bray - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “Remedies in the Officer Removal Cases,” by Samuel L. Bray. Here is the abstract: When a federal officer challenges her removal by the president, what forms of int...
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Chris Walker @chrisjwalker.bsky.social · 25/08/2025
Today the Ninth Circuit denied rehearing en banc in an important immigration case. Mike Kagan and I had filed an amicus brief urging rehearing. The panel opinion had made a mess of Loper Bright. We did get three judges dissenting, and Judge Bumatay kindly gives our brief a shoutout in his dissent:
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Dan Deacon @dtdeacon.bsky.social · 15/08/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is "Loper Bright's Disingenuity," by @cary-coglianese.bsky.social and @dfroomkin.bsky.social. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Loper Bright's Disingenuity," by Coglianese and Froomkin - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “Loper Bright’s Disingenuity,” by Cary Coglianese and David Froomkin. Here is the abstract: Loper Bright prompted a tidal wave of reaction throughout the legal com...
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Chris Walker @chrisjwalker.bsky.social · 22/08/2025
Attn adlaw nerds: Emily Bremer's JREG Comparative Administrative Law Scholarship Corner series is terrific: www.yalejreg.com/nc/comparati... If you're a legal scholar interested in comparative adlaw, I recommend signing up for the comp adlaw scholars listserv (link in post).
yalejreg.com
Comparative Administrative Law Scholarship Corner (August 2025) - Yale Journal on Regulation
Here is the list of works included in the August 2025 Comparative Administrative Law Scholarship Corner, which is curated by Eduardo Jordão (FGV Law School, Rio de Janeiro), with the assistance of Edu...
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Chris Walker @chrisjwalker.bsky.social · 14/08/2025
Attn law review editors: There are some excellent articles in the SSRN #adlaw reading list from last month that are apparently still looking for a home: www.yalejreg.com/nc/administr...
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Chris Walker @chrisjwalker.bsky.social · 14/08/2025
Over at the JREG Notice and Comment blog, Zach Price as a smart post entitled Moderating the Unitary Executive Branch in Kennedy v. Braidwood Management: www.yalejreg.com/nc/moderatin...
yalejreg.com
Moderating the Unitary Executive Branch in Kennedy v. Braidwood Management, by Zachary S. Price - Yale Journal on Regulation
The Roberts Court has sometimes hinted at supporting a strong version of the “unitary executive branch” theory—one in which Presidents can personally control all executive functions.  The Court’s hint...
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Chris Walker @chrisjwalker.bsky.social · 14/08/2025
Attn adlaw profs to share with students: Yale Law Journal Student Essay Competition: Emerging Issues in the Executive Power www.yalejreg.com/nc/yale-law-...
yalejreg.com
Yale Law Journal Student Essay Competition: Emerging Issues in the Executive Power - Yale Journal on Regulation
From the Yale Law Journal: The Yale Law Journal’s Ninth Annual Student Essay Competition challenges the next generation of legal scholars and practitioners to reflect on emerging legal problems. This ...
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Michigan Law @umichlaw.bsky.social · 12/08/2025
New draft on @ssrn.bsky.social: Stare Decisis and the Missing Administrability Inquiry By Professor @chrisjwalker.bsky.social and @andrewshammond.bsky.social (@iumaurerlaw.bsky.social) @ssrn.bsky.social: papers.ssrn.com/sol3/papers....
Screenshot of the following text: Stare Decisis and the Missing Administrability Inquiry
New York University Law Review (forthcoming 2025)

U of Michigan Public Law Research Paper No. 25-004

40 Pages Posted: 7 Aug 2025 Last revised: 11 Aug 2025
Andrew Hammond
Indiana University Maurer School of Law

Christopher J. Walker
University of Michigan Law School

Date Written: August 06, 2025

Abstract
Administrative law is undergoing a tremendous amount of change. Presidential administrations have abandoned long-held practices and embraced new strategies to make policy through adjudication and regulation. Meanwhile, the Supreme Court has reworked foundational principles of federal administrative law including agency independence, adjudication, and legal interpretation. What does the pace and degree of change in administrative law mean for the federal courts? We posit that some answers lie in the Supreme Court’s decision in Kisor v. Wilkie and its application in the lower courts over the last five years.

In Kisor v. Wilkie, the Court was asked to reconsider its longstanding precedents concerning judicial deference to federal agencies’ interpretations of their own regulations. The result was a splintered decision that produced more questions than answers. Justice Kagan, writing for the plurality (and in parts, the Court), reaffirmed those precedents, including Auer and Seminole Rock, but also clarified and expanded the ways in which such deference should be constrained. Justice Gorsuch penned the principal opposing opinion, arguing that the Court should abandon Auer deference entirely. Chief Justice Roberts cast the deciding vote based on stare decisis, suggesting that “the
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Chris Walker @chrisjwalker.bsky.social · 13/08/2025
New to SSRN: Andrew Hammond and I have posted a draft of a symposium essay from our Kisor dataset, entitled The End of Administrative Pragmatism? This one explores how Kisor, Loper Bright, and Consumers' Research affect theories in administrative law. Link here: papers.ssrn.com/sol3/papers....
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Kristin E. Hickman @khickmanjd.bsky.social · 07/08/2025
For users of the Hickman, Pierce, & Walker federal admin law textbook, @chrisjwalker.bsky.social has posted the link to our summer supplement at the Notice & Comment blog. We're working on the 5th edition. Feedback from users is always welcome.
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Chris Walker @chrisjwalker.bsky.social · 07/08/2025
Last week Kristin Hickman, Dick Pierce, and I finished the 2025 summer update to our federal administrative law casebook. The 5th Edition will be available next summer! Details and link to update: www.yalejreg.com/nc/summer-20...
yalejreg.com
Summer 2025 Update to the Hickman-Pierce-Walker Federal Administrative Law: Cases and Materials - Yale Journal on Regulation
Kristin, Dick, and I have just published the Summer 2025 Update to our federal administrative law casebook. From the introduction: Administrative law is a dynamic field, and there are always interesti...
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Chris Walker @chrisjwalker.bsky.social · 06/08/2025
New to SSRN: Andrew Hammond and I have posted a draft of Stare Decisis and the Missing Administrability Inquiry: papers.ssrn.com/sol3/papers.... This is the first paper from our Kisor dataset, and it includes our findings from reviewing all lower-court decisions that invoke Kisor from 2019-2024.
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Dan Deacon @dtdeacon.bsky.social · 01/08/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room covers two pieces: "Presidential Brokering in the Regulatory State" by @jennifernou.bsky.social and "The Chadha Presidency" by @joshchafetz.bsky.social. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Presidential Brokering in the Regulatory State," by Nou & "The Chadha Presidency," by Chafetz - Yale Journal on Regulation
Today’s Ad Law Reading Room brings two entries. The first is “Presidential Brokering in the Regulatory State,” forthcoming in the George Washington Law Review, by Jennifer Nou. The second is “The Chad...
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Chris Walker @chrisjwalker.bsky.social · 24/07/2025
Over at Jotwell, I review Kevin Stack's terrific article The Internal Law of Democracy: adlaw.jotwell.com/shifting-att...
adlaw.jotwell.com
Shifting Attention to Internal Administrative Law in the States - Administrative Law
Kevin M. Stack, The Internal Law of Democracy, 77 Vand. L. Rev. 1627 (2024).Christopher WalkerIn Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519, 524 (1978), the Supreme Court famously announ...
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Dan Deacon @dtdeacon.bsky.social · 15/07/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is “The Gray Area: Finding Implicit Delegation to Agencies after Loper Bright,” by Matthew Stephenson. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "The Gray Area: Finding Implicit Delegation to Agencies after Loper Bright," by Matthew Stephenson - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “The Gray Area: Finding Implicit Delegation to Agencies after Loper Bright,” by Matthew Stephenson. Here is the abstract: In Loper Bright v. Raimondo, the Supreme ...
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Dan Deacon @dtdeacon.bsky.social · 30/06/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is "New Challenges for Federal Regulations: Executive Branch Responses," by Richard Revesz. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "New Challenges for Federal Regulations: Executive Branch Responses," by Richard Revesz - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “New Challenges for Federal Regulations: Executive Branch Responses,” by Richard L. Revesz, which is forthcoming in the NYU Law Review. Here is the abstract: Over ...
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Michigan Law @umichlaw.bsky.social · 30/06/2025
New from Professor @chrisjwalker.bsky.social: What FCC v. Consumers’ Research Means for the Future of the Nondelegation Doctrine www.yalejreg.com/nc/what-fcc-...
yalejreg.com
What FCC v. Consumers' Research Means for the Future of the Nondelegation Doctrine - Yale Journal on Regulation
On Friday, the Supreme Court issued a 6-3 decision in FCC v. Consumers’ Research, rejecting a nondelegation doctrine challenge to the constitutionality of the FCC’s Universal Service Fund. Writing for...
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Chris Walker @chrisjwalker.bsky.social · 12/06/2025
Attn #adlaw geeks: Call for Panel Proposals -- 2025 ABA Administrative Law Conference (11/20-11/21) www.yalejreg.com/nc/call-for-...
yalejreg.com
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Dan Deacon @dtdeacon.bsky.social · 10/06/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is “Designing Policymaking Mechanisms for Regulatory Dynamism,” by Julie E. Cohen, Nina-Simone Edwards, Meg Leta Jones, and @paulohm.bsky.social. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Designing Policymaking Mechanisms for Regulatory Dynamism," by Cohen, Edwards, Jones, and Ohm - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “Designing Policymaking Mechanisms for Regulatory Dynamism,” by Julie E. Cohen, Nina-Simone Edwards, Meg Leta Jones, and Paul Ohm. Here is the abstract: The admini...
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Dan Deacon @dtdeacon.bsky.social · 23/05/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is “The Lost English Roots of Notice-and-Comment Rulemaking,” by Rephael Stern. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "The Lost English Roots of Notice-and-Comment Rulemaking," by Rephael Stern - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “The Lost English Roots of Notice-and-Comment Rulemaking,” by Rephael G. Stern, which was recently published by the Yale Law Journal and posted to SSRN.  Here is t...
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Dan Deacon @dtdeacon.bsky.social · 05/05/2025
New paper from me and @leahlitman.bsky.social, entitled "Legalistic Noncompliance," taking stock of the second Trump administration's emerging practice with respect to judicial orders. It's on the "draft-y" side -- comments welcomed! papers.ssrn.com/sol3/papers....
papers.ssrn.com
Legalistic Noncompliance
Will the executive branch comply with court orders? That question has garnered a considerable amount of attention over the first few months of the second Trump
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Dan Deacon @dtdeacon.bsky.social · 28/04/2025
Over at the Notice and Comment blog, today's Ad Law Reading Room entry is "Appropriations Presidentialism," by @mblawrence.bsky.social, Eloise Pasachoff, and Zachary Price. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Appropriations Presidentialism," by Lawrence, Pasachoff, and Price - Yale Journal on Regulation
Today’s Ad Law Reading Room entry is “Appropriations Presidentialism,” by Matthew B. Lawrence, Eloise Pasachoff, and Zachary S. Price, which is forthcoming in the Georgetown Law Journal Online. Here i...
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Chris Walker @chrisjwalker.bsky.social · 24/04/2025
To be mentioned in the same sentence as @primuseve.bsky.social and teaching excellence is an honor. Eve sets the high bar for teaching excellence here @umichlaw.bsky.social.
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Michigan Law @umichlaw.bsky.social · 24/04/2025
LSSS has announced the winners of the '24–'25 teaching awards. Prof @primuseve.bsky.social won the L. Hart Wright Award for Excellence in Teaching, and Profs Howard Bromberg, Mira Edmonds, and @chrisjwalker.bsky.social also received student-nominated awards. michigan.law.umich.edu/news/michiga...
michigan.law.umich.edu
Michigan Law Students Recognize Bromberg, Edmonds, Primus, and Walker with 2025 Teaching Awards | University of Michigan Law School
The Law School Student Senate (LSSS) has announced the winners of the 2024–2025 teaching awards.
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Chris Walker @chrisjwalker.bsky.social · 18/04/2025
Last week at the NYU Law Review/Policy Integrity Institute symposium, I was part of a really cool panel on how we would rethink administrative law if we were writing on a clean slate. Here's the video (at the start of my remarks): youtu.be/77YyfLnNhzE?...
youtu.be
Symposium Panel 2: Building On A Clean Slate
YouTube video by Institute for Policy Integrity
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Chris Walker @chrisjwalker.bsky.social · 13/04/2025
Attn #adlaw nerds: Join Us on May 8, 2025, for the ABA Administrative Law Scholarship Conference -- 30 papers to be workshopped, ~50 scholars presenting and commenting, and plenty of time to socialize. Complimentary registration details here: www.yalejreg.com/nc/join-us-o...
yalejreg.com
Join Us on May 8, 2025, for the ABA Administrative Law Scholarship Conference - Yale Journal on Regulation
On Thursday May 8, 2025, in Washington, DC, the ABA Section of Administrative Law and Regulatory Practice is hosting a terrific scholarship conference that will feature paper presentations and comment...
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Kristin E. Hickman @khickmanjd.bsky.social · 12/04/2025
Congrats to @nyulawreview.bsky.social & @policyintegrity.bsky.social for a fantastic symposium. Interesting & timely remarks from @chris_j_walker & many others. So grateful for the opportunity to join & highlight Harmonizing Delegation & Deference After Loper Bright. papers.ssrn.com/sol3/papers....
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Joanna Grisinger @grisinger.bsky.social · 11/04/2025
Looking forward to presenting today! Eager to talk about an agency that hasn’t existed for 40 years.
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Chris Walker @chrisjwalker.bsky.social · 11/04/2025
The @nyulawreview.bsky.social and @policyintegrity.bsky.social have organized a terrific administrative law symposium today. My @umichlaw.bsky.social colleague @jdmortenson.bsky.social is here to talk about history, and I'm on a panel that is charged with ignoring history. 🤓
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Dan Deacon @dtdeacon.bsky.social · 10/04/2025
Today's Ad Law Reading Room features two recently posted articles: "Presidential Administration After Arthrex," by @narosenblum.bsky.social & @rickhills.bsky.social and "Science and Politics in Public Health Regulation," by @sbagen.bsky.social. Check it out! www.yalejreg.com/nc/ad-law-re...
yalejreg.com
Ad Law Reading Room: "Presidential Administration After Arthrex," by Rosenblum & Hills and "Science and Politics in Public Health Regulation," by Bagenstos - Yale Journal on Regulation
Today’s Ad Law Reading Room delivers a twofer (you’re welcome). The first entry is “Presidential Administration After Arthrex,” by Noah A. Rosenblum & Roderick M. Hills, Jr. The second is “Science and...
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Chris Walker @chrisjwalker.bsky.social · 09/04/2025
It was an honor and thrill to be interviewed by Judge Diane Wood today at this National Academies of Science, Engineering, and Medicine workshop on the future of administrative law at the Supreme Court.
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Dan Deacon @dtdeacon.bsky.social · 02/04/2025
Congrats to @chrisjwalker.bsky.social and @nbagley.bsky.social for being cited in today's big arbitrary-and-capricious opinion (alongside some guy named "H. Friendly")!
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