Expansion of Expedited Removal
https://www.federalregister.gov/documents/2019/07/23/2019-15710/designating-aliens-for-expedited-removal
Write 3-5 sentences discussing whether the expansion of expedited removal should have gone through Notice and Comment
before being implemented. You may want to consider the following questions: (1) Are you persuaded that the good cause exception to N&C applies? (in other words, that it would be impractical, unnecessary, or contrary to the public interest to go through N&C?); (2) Is DHS’s “discretionary” request for comments after making the change effective an adequate substitute?
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