question
Why Do We Need Administrative Agencies?
answer
-Continuing Enforcement Issues
-Need for Industry Specific Expertise
-Changing Conditions in the Area of Interest
-Need for Industry Specific Expertise
-Changing Conditions in the Area of Interest
question
Agencies Provide a Comprehensive Regulatory Scheme:
answer
Administrative agencies at various levels work together and share the responsibility of creating and enforcing particular regulations.
question
Administrative Agencies Exist at All Levels of Government:
answer
Federal agency regulations take precedence over conflicting state regulations.
question
How does congress create administrative agencies?
answer
To create an administrative agency [AA], Congress passes enabling legislation that specifies the name, purposes, functions, and powers of the agency.
question
What powers can federal administrative agencies exercise?
answer
Federal administrative agencies can exercise only those powers that are delegated to them in the legislation.
question
What was arguably the first administrative agency?
answer
The Interstate Commerce Commission b.1887 d.1995
question
Mission of the Interstate Commerce Commission
answer
-To Ban "personal discrimination"
-Shipping rates to be "just and reasonable."
-Shipping rates to be "just and reasonable."
question
Enabling Legislation
answer
A statute enacted by Congress that authorizes the creation of an administrative agency and specifies the name, composition, purpose, and powers of the agency being created.
-Enabling statute defines AA legal authority.
-AA cannot regulate beyond its enabling legislation
-AA may also be required to take some regulatory action by the terms of that statute.
-Enabling statute defines AA legal authority.
-AA cannot regulate beyond its enabling legislation
-AA may also be required to take some regulatory action by the terms of that statute.
question
Delegation Doctrine
answer
A doctrine that says when an administrative agency is created, it is delegated certain powers; the agency can use only the legislative, judicial, and executive powers that are delegated to it.
question
Environmental Protection Agency (EPA)
answer
an independent federal agency established to coordinate programs aimed at reducing pollution and protecting the environment
Created in 1970 by Congress to unify and consolidate environmental law.
-When Congress passes a new law, the EPA issues regulations to implement it.
-The EPA can bring an action against violators.
-Some infractions have criminal penalties, though most are civil violations.
Created in 1970 by Congress to unify and consolidate environmental law.
-When Congress passes a new law, the EPA issues regulations to implement it.
-The EPA can bring an action against violators.
-Some infractions have criminal penalties, though most are civil violations.
question
four provisions of the Clean Air Act of 1970
answer
1. Primary Standards
2.Secondary Standards
3.State Implementation Plans (SIPs)
4.Citizen Suits
2.Secondary Standards
3.State Implementation Plans (SIPs)
4.Citizen Suits
question
1. Primary Standards
answer
national ambient air quality standards for pollution that harms public health. Upheld, regardless of cost.
question
2.Secondary Standards
answer
standards set for less harmful, but unpleasant pollution.
question
3.State Implementation Plans (SIPs)
answer
the EPA can produce its own plan of pollution reduction if a state's plan is not implemented in a reasonable time.
question
4.Citizen Suits
answer
allows anyone to file a suit against a polluter or against the EPA for failure to enforce environmental rules.
question
The Environmental Protection Agency (EPA) was created by Congress to:
answer
...
question
T or F
Administrative agencies exist at the federal, state, and local levels.
Administrative agencies exist at the federal, state, and local levels.
answer
...
question
True or False?
We Care, a nonprofit environmental organization, believes that Quanaco is violating the Clean Air Act. The EPA has not taken any action against Quanaco. We Care can file a citizens' suit against the EPA.
We Care, a nonprofit environmental organization, believes that Quanaco is violating the Clean Air Act. The EPA has not taken any action against Quanaco. We Care can file a citizens' suit against the EPA.
answer
...
question
Loving v. IRS, 742 F.3d 1013 (D.C. Cir. 2014)(Kavanaugh, J)
answer
-IRS passed a rule to regulate tax preparers
-Enabling legislation gave IRS authority "to regulate the practice of representatives of persons before" it.
-Tax preparers aren't representatives
-They're not practicing before the IRS
-Other laws specifically mention "tax preparers"; this law didn't
-Huge expansion of authority never sought before by IRS
---HELD: IRS exceeded its authority
-Enabling legislation gave IRS authority "to regulate the practice of representatives of persons before" it.
-Tax preparers aren't representatives
-They're not practicing before the IRS
-Other laws specifically mention "tax preparers"; this law didn't
-Huge expansion of authority never sought before by IRS
---HELD: IRS exceeded its authority
question
If an agency has statutory authority to manage forests on federal lands to prevent wildfires, would a regulation licensing food vendors in federal parks exceed its enabling legislation?
answer
...
question
What are the 2 types of administrative agencies?
answer
1. Executive Federal Agency
2. Independent Federal Agency
2. Independent Federal Agency
question
Executive Federal Agency:
answer
Part of executive branch, under the control of the President; usually support the President's policies. Examples: FBI, IRS, FDA, Nuclear Regulatory Commission
question
Why was the IRS originally created?
answer
-B. 1862
-To pay for Civil War
-To collect income tax- ups and downs
-16th Am passed in 1913-That was an UP!
-IRS commissioner and chief counsel- selected by the president and confirmed by the Senate.
Commissioner - David J. Kautter (acting)
IRS Chief Counsel — Vacant
-To pay for Civil War
-To collect income tax- ups and downs
-16th Am passed in 1913-That was an UP!
-IRS commissioner and chief counsel- selected by the president and confirmed by the Senate.
Commissioner - David J. Kautter (acting)
IRS Chief Counsel — Vacant
question
Independent Federal Agency:
answer
Not part of executive branch; President does not have the power to fire the head of the agency. Examples: FTC, FCC, SEC, EPA, NLRB
question
SEC
answer
Five Commissioners
-Staggered Terms, every June 5
-Nominated by President
-Confirmed by Senate
-No More than Three of Same Party
-Prez Picks a Commish to be Chair
-Staggered Terms, every June 5
-Nominated by President
-Confirmed by Senate
-No More than Three of Same Party
-Prez Picks a Commish to be Chair
question
What is the major distinction between executive and independent agencies?
answer
president has greater control over exec agencies
question
T or F
The President has the power to remove the chairperson of the Consumer Product Safety Commission, an independent federal administrative agency, if the President disagrees with the chairperson's actions.
The President has the power to remove the chairperson of the Consumer Product Safety Commission, an independent federal administrative agency, if the President disagrees with the chairperson's actions.
answer
false
question
2 types of rules AA can make
answer
Two types of rules
Legislative [substantive]rules -
Interpretive rules -
-These [substantive or legislative] Rules Have the Force of Law
-But Must be Properly Enacted
Legislative [substantive]rules -
Interpretive rules -
-These [substantive or legislative] Rules Have the Force of Law
-But Must be Properly Enacted
question
Legislative [substantive]rules -
answer
require businesses and people to act a certain way; have the effect of a Congressional statute;
Must be adopted in compliance with APA.
Must be adopted in compliance with APA.
question
Interpretive rules -
answer
these do not affect the rights of parties;
they define or apply the laws to new situations
Are exempt from the APA process.
they define or apply the laws to new situations
Are exempt from the APA process.
question
OSHA (Occupational Safety and Health Administration)
answer
...
question
The Administrative Procedure Act
answer
-Passed in 1946 to bring uniformity and control to many federal agencies.
-Regulates how federal agencies
make rules,
-conduct investigations,
-hold meetings and hearings,
-reach decisions and
-obtain and release info
-Regulates how federal agencies
make rules,
-conduct investigations,
-hold meetings and hearings,
-reach decisions and
-obtain and release info
question
For Rulemaking the APA requires
answer
Notice
Comment Period
Then, the Final Rule is Published
Comment Period
Then, the Final Rule is Published
question
The Administrative Procedure Act-Notice
answer
Notice:
-Proposed Rule Must be Published in The Federal Register
-For Example, 9/20/18: The FMCSA announces that it will hold a public listening session concerning potential changes to its hours-of-service (HOS) rules for truck drivers.
-Time and Place given
-Proposed Rule Must be Published in The Federal Register
-For Example, 9/20/18: The FMCSA announces that it will hold a public listening session concerning potential changes to its hours-of-service (HOS) rules for truck drivers.
-Time and Place given
question
The
Administrative Procedure Act-
Comment Period
Administrative Procedure Act-
Comment Period
answer
Comment:
written or
oral (if hearing held)
written or
oral (if hearing held)
question
The Administrative Procedure Act-Final Rule
answer
The Final Rule Must
Contain a Summary
Explain Its Purpose
Be Published in Federal Register
Contain a Summary
Explain Its Purpose
Be Published in Federal Register
question
Interpretive Rules and Guidance Don't Require a Formal Public Process
answer
Declare Policy
Don't Affect Legal Rights
Shot Across Bow of the Regulated-If you argue about our interpretation, we will do a formal rule
Don't Affect Legal Rights
Shot Across Bow of the Regulated-If you argue about our interpretation, we will do a formal rule
question
Yesler Terrace Comm. Council v. Cisneros, 37 F.3d 442
(9th Cir. 1994)
(9th Cir. 1994)
answer
Held: A substantive rule affects procedures and rights. Before this decision, tenants had a right to a hearing, after it they didn't. That's a substantive rule. There was no Notice and Comment; Violation of APA; new rule void.
question
True or False?
An interpretative rule merely states policy and doesn't affect legal rights and is exempt from the rule-making requirements of the Administrative Procedure Act.
An interpretative rule merely states policy and doesn't affect legal rights and is exempt from the rule-making requirements of the Administrative Procedure Act.
answer
...
question
True or False?
Final administrative rules have binding legal effect, and are called legislative or substantive.
Final administrative rules have binding legal effect, and are called legislative or substantive.
answer
...
question
Which law regulates how federal agencies make rules, conduct investigations, hold meetings and hearings, obtain information, and reach decisions?
a. The 1964 Civil Rights Act.
b. The Clean Agency Act.
c. The Administrative Procedure Act.
d. The Freedom of Information Act.
a. The 1964 Civil Rights Act.
b. The Clean Agency Act.
c. The Administrative Procedure Act.
d. The Freedom of Information Act.
answer
...
question
To notify the public of a proposed rule, the Federal Emergency Management Agency, like other federal agencies, publishes the proposal?
a. On PBS.
b. In an appropriate trade journal.
c. In The Federal Register.
d. On its web site. Information Act.
a. On PBS.
b. In an appropriate trade journal.
c. In The Federal Register.
d. On its web site. Information Act.
answer
...
question
The Securities and Exchange Commission decides to create a new rule relating to the dissemination of material nonpublic information through corporate blogs, tweets, and Web sites. The first step is to
answer
a. compile the rule with others in the Code of Federal Regulations.
b. conduct an on-site inspection.
c. publish a notice of the proposed rulemaking.
d. solicit public comment.
b. conduct an on-site inspection.
c. publish a notice of the proposed rulemaking.
d. solicit public comment.
question
True or False?
Federal Administrative agencies' final rules are published in the United States Code
Federal Administrative agencies' final rules are published in the United States Code
answer
...
question
Power of Agencies -- Investigation
answer
-Once the rule is made, the agency will enforce it
-Voluntary Cooperation
-OR "Involuntary Cooperation"...(JK)
Subpoena --
-Voluntary Cooperation
-OR "Involuntary Cooperation"...(JK)
Subpoena --
question
subpoena
answer
an order to appear at a hearing and produce evidence, sometimes documents.
-Must be relevant
-Must not be unreasonably burdensome
-Must not be privileged
-Must be relevant
-Must not be unreasonably burdensome
-Must not be privileged
question
2 types of subpoenas
answer
1. Subpoena Ad testificandum-requiring testimony
2. Subpoena Duces Tecum-demanding documents
2. Subpoena Duces Tecum-demanding documents
question
True or False?
The power of an AA to issue subpoenas is unlimited.
The power of an AA to issue subpoenas is unlimited.
answer
...
question
True or False?
A subpoena ad testificandum is an order to an individual or organization to hand over certain records, papers, or books.
A subpoena ad testificandum is an order to an individual or organization to hand over certain records, papers, or books.
answer
...
question
Can the AA search a business in order to gather evidence?
answer
-THE GENERAL RULE=Most searches require a WARRANT.
-The standard is not like criminal law
-Probable cause to issue an administrative warrant exists
-Exception to Warrant Requirement: emergencies
-The standard is not like criminal law
-Probable cause to issue an administrative warrant exists
-Exception to Warrant Requirement: emergencies
question
Exception to Warrant Requirement:
answer
CLOSELY REGULATED BUSINESS EXCEPTION.
question
CLOSELY REGULATED BUSINESS EXCEPTION-
answer
Some industries are closely regulated[aka "pervasively regulated"] and may be searched at any time, with no warning.
For example,
liquor,
firearms,
mines,
automobile-junkyard and vehicle-dismantling industry
NOT A BROAD EXCEPTION TO WARRANT REQUIREMENT
If Business Refuses, AA must go to Court for an order or Can impose immediate penalty
For example,
liquor,
firearms,
mines,
automobile-junkyard and vehicle-dismantling industry
NOT A BROAD EXCEPTION TO WARRANT REQUIREMENT
If Business Refuses, AA must go to Court for an order or Can impose immediate penalty
question
True or False?
In most instances, an agency is required to obtain a search warrant before a physical search for evidence is conducted.
In most instances, an agency is required to obtain a search warrant before a physical search for evidence is conducted.
answer
...
question
True or False?
There are no situations in which an administrative agency can conduct a warrantless search.
There are no situations in which an administrative agency can conduct a warrantless search.
answer
...
question
Under the closely regulated business exception
Businesses such as firearms and liquor are heavily regulated.
Warrants are not required to allow AA's to search certain businesses, such as firearms and liquor, because there is no expectation of privacy
Businesses such as hotels, and child care agencies can be searched without a warrant
Capital gains taxes are not imposed.
Businesses such as firearms and liquor are heavily regulated.
Warrants are not required to allow AA's to search certain businesses, such as firearms and liquor, because there is no expectation of privacy
Businesses such as hotels, and child care agencies can be searched without a warrant
Capital gains taxes are not imposed.
answer
...
question
Power of Agencies -- Adjudication
answer
-Civil penalties may be imposed by the AA after hearing.
-An Adjudicatory hearing...an adjudication: i.e, to make an official decision, to decide judicially
-Complaint or charging document is filed
-Administrative law judge [ALJ] presides
-Parties have counsel
-No jury.
-Informal; both sides present evidence
-Judge makes ruling on testimony and evidence, hearsay is allowed
-If parties are unhappy with results
-Loser may appeal to the commission that runs the AA.
-Commission may make a de novo [a new] decision, and ignore the administrative law judge's decision.
-Appeals go to a federal appellate court. E.g., the 7th Circuit.
-An Adjudicatory hearing...an adjudication: i.e, to make an official decision, to decide judicially
-Complaint or charging document is filed
-Administrative law judge [ALJ] presides
-Parties have counsel
-No jury.
-Informal; both sides present evidence
-Judge makes ruling on testimony and evidence, hearsay is allowed
-If parties are unhappy with results
-Loser may appeal to the commission that runs the AA.
-Commission may make a de novo [a new] decision, and ignore the administrative law judge's decision.
-Appeals go to a federal appellate court. E.g., the 7th Circuit.
question
Adjudicate --
answer
means to hold a hearing, then decide how to proceed with an issue.
question
What is Hearsay?
answer
An out of court statement by a declarant offered to prove the truth of the matter asserted.
Example: If the story is being told by someone not in the witness stand, it's probably hearsay.
Example of an out of court statement by a declarant NOT offered to prove the truth of the matter asserted.
Testimony in a divorce custody case that the child said her dolly "was very very sad" after daddy moved out.
Testimony in a mental health commitment hearing that the respondent said "I am from the planet Xenon."
Example: If the story is being told by someone not in the witness stand, it's probably hearsay.
Example of an out of court statement by a declarant NOT offered to prove the truth of the matter asserted.
Testimony in a divorce custody case that the child said her dolly "was very very sad" after daddy moved out.
Testimony in a mental health commitment hearing that the respondent said "I am from the planet Xenon."
question
Likely hearsay in AA hearing:
answer
Reports
Medical records
Affidavits (formal written statements by a witness under oath)
What another person said to the witness
Medical records
Affidavits (formal written statements by a witness under oath)
What another person said to the witness
question
True or False?
An ALJ's decision is not final until the full commission has issued its decision on the complaint. After the commission has ruled, the loser may appeal to the federal intermediate appellate court.
An ALJ's decision is not final until the full commission has issued its decision on the complaint. After the commission has ruled, the loser may appeal to the federal intermediate appellate court.
answer
...
question
True or False?
Hearsay is an out-of-court statement by a declarant offered to prove the truth of the matter asserted.
Hearsay is an out-of-court statement by a declarant offered to prove the truth of the matter asserted.
answer
...
question
AA's Power is Checked by The Administrative Procedure Act
answer
The APA provides that courts should "hold unlawful and set aside" agency actions found to be either:
-"arbitrary, capricious, an abuse of discretion, or
-otherwise not in accordance with law."
-"Otherwise not in accordance with law"
E.g., Loving v. IRS, the case where IRS tried to make a rule outside of its enabling authority
-"arbitrary, capricious, an abuse of discretion, or
-otherwise not in accordance with law."
-"Otherwise not in accordance with law"
E.g., Loving v. IRS, the case where IRS tried to make a rule outside of its enabling authority
question
Arbitrary and Capricious :
answer
1. Failed to provide a rational explanation for its decision.
2. Changed its prior policy without justification.
3. Considered legally inappropriate factors.
4.Entirely failed to consider a relevant factor.
5. Rendered a decision plainly contrary to the evidence.
2. Changed its prior policy without justification.
3. Considered legally inappropriate factors.
4.Entirely failed to consider a relevant factor.
5. Rendered a decision plainly contrary to the evidence.
question
Speaking of Deference: Chevron
answer
Remember the Clean Air Act Allows citizen Suits?
An environmental group sued the EPA over its interpretation of a statute.
The statute required EPA to permit "new or modified major stationary sources" of air pollution.
President Carter's EPA said one thing
President Reagan's EPA said another
Lawsuit-Chevron was affected party
SCOTUS Ruling: EPA won.
"[I]f the statute is silent or ambiguous ..., the question ...is whether the agency's answer is based on a permissible construction of the statute."
Id. At 842-43
An environmental group sued the EPA over its interpretation of a statute.
The statute required EPA to permit "new or modified major stationary sources" of air pollution.
President Carter's EPA said one thing
President Reagan's EPA said another
Lawsuit-Chevron was affected party
SCOTUS Ruling: EPA won.
"[I]f the statute is silent or ambiguous ..., the question ...is whether the agency's answer is based on a permissible construction of the statute."
Id. At 842-43
question
Chevron Deference
answer
means a court should defer to [or give respect to] an agency's interpretation of law if reasonable, even if the court might have interpreted it differently
Example of Chevron deference:
Mayo Foundation for Medical Education and Research v. United States (SCOTUS 2011)(The "student"-doctors and the tax break)
Example of Chevron deference:
Mayo Foundation for Medical Education and Research v. United States (SCOTUS 2011)(The "student"-doctors and the tax break)
question
When Courts Will Give Chevron
Deference to Agency Interpretation:
Deference to Agency Interpretation:
answer
-More likely when they meet the formal legal standards for notice-and-comment rulemaking. Encino Motorcars v. Navarro, SCOTUS 2016
-Not when the AA is arbitrary and capricious
-Maybe not other times: like ... interpretative informal actions
-Not when the AA is arbitrary and capricious
-Maybe not other times: like ... interpretative informal actions
question
True or False?
Chevron deference refers to the deference given an AA's interpretation of an enabling ambiguous statute; If the AA's interpretation is reasonable, the courts will rule for the agency.
Chevron deference refers to the deference given an AA's interpretation of an enabling ambiguous statute; If the AA's interpretation is reasonable, the courts will rule for the agency.
answer
...
question
Chevron deference
Refers to
Refers to
answer
the deference given an AA's interpretation of an enabling ambiguous statute
Means that if the AA's interpretation is reasonable, the courts will rule for the agency.
Is somewhat controversial lately among SCOTUS
All of the choices
Means that if the AA's interpretation is reasonable, the courts will rule for the agency.
Is somewhat controversial lately among SCOTUS
All of the choices
question
AA Powers Judicial Controls:
answer
The judicial branch exercises control over agency powers through the courts' review of agency actions.
question
AA Powers Exhaustion Doctrine
answer
Agency actions are not automatically subject to judicial review. Under the exhaustion doctrine, the party seeking court review must first exhaust all administrative remedies.
question
AA Powers and Executive Controls:
answer
The executive branch of government exercises control over agencies via the president's power to appoint federal officers and through the president's veto power.
question
AA Powers and Legislative Controls:
answer
Congress can
-abolish an agency
-investigate AA's
-Power of the Purse! Starve their budget!
-abolish an agency
-investigate AA's
-Power of the Purse! Starve their budget!
question
Congressional Review Act-
answer
Congress also has the power to "freeze" the enforcement of most federal regulations before they take effect.
question
The Congressional Review Act (CRA)
5 USC 801 et seq.
5 USC 801 et seq.
answer
-1996 law
-Congress has 60 legislative working days to disapprove
Not 60 days, 60 Legislative Days!
-Resolutions of Disapproval [RoD]
are expedited -no committees or filibusters
Like any other legislation, President could veto
***Once disapproved, AA can NEVER make a similar rule
Example: Was used once between 1996 -2016 to void a reg
In 2017, used 14 times to void Obama-era regs
Reached back to May, 2016
-Congress has 60 legislative working days to disapprove
Not 60 days, 60 Legislative Days!
-Resolutions of Disapproval [RoD]
are expedited -no committees or filibusters
Like any other legislation, President could veto
***Once disapproved, AA can NEVER make a similar rule
Example: Was used once between 1996 -2016 to void a reg
In 2017, used 14 times to void Obama-era regs
Reached back to May, 2016
question
Freedom of Information Act (FOIA)
answer
requires the federal government to disclose certain records to any person or entity on written request, even if no reason is given for the request.
--All federal government agencies must make their records available electronically on the Internet and in other electronic formats.
-The FOIA exempts certain types of records such as those pertaining to national security and those containing confidential or personal information.
-An agency's failure to comply with an FOIA request can be challenged in a federal district court.
--All federal government agencies must make their records available electronically on the Internet and in other electronic formats.
-The FOIA exempts certain types of records such as those pertaining to national security and those containing confidential or personal information.
-An agency's failure to comply with an FOIA request can be challenged in a federal district court.
question
Government in the Sunshine Act:
answer
The legislative intent of the Act is as follows: "The basic premise of the sunshine legislation is that, in the words of federalist No. 49, 'the people are the only legitimate foundation of power, and it is from them that the constitutional charter ... is derived.' Government is and should be the servant of the people, and it should be fully accountable to them for the actions which it supposedly takes on their behalf."
-a/k/a open meetings act
-"every portion of every meeting of an agency" must be open to "public observation" -some exceptions
-notice of scheduled meetings and agendas.
Most states have Open Meetings Acts
IL has a very strong statute
Criminal Penalties and Other Enforcement
-a/k/a open meetings act
-"every portion of every meeting of an agency" must be open to "public observation" -some exceptions
-notice of scheduled meetings and agendas.
Most states have Open Meetings Acts
IL has a very strong statute
Criminal Penalties and Other Enforcement
question
Regulatory Flexibility Act:
answer
-agency must conduct a regulatory flexibility analysis of cost of new rule on small businesses and consider less burdensome alternatives.
-Alerts to small businesses re new reg's.
-Alerts to small businesses re new reg's.
question
Small Business Regulatory Enforcement Fairness Act:
answer
-intended to ease the regulatory burden on small businesses
-Requires plain English guides that explain compliance
-Ratings!
-Requires plain English guides that explain compliance
-Ratings!
question
The power of federal agencies is limited by:
a. statutory control in the enabling legislation and the Administrative Procedures Act.
b. political control by Congress and the President.
c. judicial review.
d. All of the above.
a. statutory control in the enabling legislation and the Administrative Procedures Act.
b. political control by Congress and the President.
c. judicial review.
d. All of the above.
answer
...
question
TECO Coal Corporation is interested in the inspections that the U.S. Bureau of Mines has conducted over the past year. To secure this information, TECO should:
a. issue a subpoena duces tecum.
b. make a Freedom of Information Act request.
c. make a de novo request.
d. assert the substantial evidence rule.
a. issue a subpoena duces tecum.
b. make a Freedom of Information Act request.
c. make a de novo request.
d. assert the substantial evidence rule.
answer
...
question
A failure of the FBI to comply with
a request under the Freedom of
Information Act (FOIA) may be challenged in
a. a federal district court.
b. a hearing before the U.S. Freedom of Information Agency.
c. a meeting with Congress's FOIA subcommittee.
d. a special conference with the president of the United States.
a request under the Freedom of
Information Act (FOIA) may be challenged in
a. a federal district court.
b. a hearing before the U.S. Freedom of Information Agency.
c. a meeting with Congress's FOIA subcommittee.
d. a special conference with the president of the United States.
answer
...
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