Air Transport Association of America v. Department of Transportation
United States Court of Appeals for the District of Columbia Circuit
900 F.2d 369 (1990)
Relevant factsFree
Congress authorized the FAA to run a demonstration program adjudicating certain aviation civil penalties, and the FAA then issued detailed "Penalty Rules" covering the entire adjudicatory process — schedules of penalties, formal notice, discovery, hearings before an ALJ, and appeals — without going through APA notice-and-comment rulemaking, relying on the APA's exemptions for procedural rules and for "good cause."
IssueFree
Whether the APA requires an agency to use notice-and-comment procedures before promulgating a comprehensive body of rules governing the adjudication of administrative penalty actions.
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