Administrative law’s conventional mechanisms for bolstering democratic accountability are under strain. Open-access procedures like notice-and-comment rulemaking promise to inject a dose of popular responsiveness into agency decision-making. Well-resourced groups’ outsized use of these...

A world in turmoil caused by COVID-19 has revealed again what has long been true: the Federal Reserve is arguably the most powerful administrative agency in government, but neither administrative-law scholars nor the Fed itself treat it that way. In this Article, we present the first effort to...