Brief of Professors William Araiza, Jeffrey Lubbers, and Peter M. Shane as Amici Curiae in Support of Defendantappellant Federal Trade Commission

Amici are law professors who teach and write in the fields of administrative law and statutory interpretation. Amicus William Araiza is the Stanley A. August Professor of Law at Brooklyn Law School. Amicus Jeffrey Lubbers is Professor of Practice in Administrative Law at American University, Washington College of Law. Amicus Peter M. Shane is the Jacob E. Davis and Jacob E. Davis II Chair in Law Emeritus at Ohio State University, Moritz College of Law. As leading administrative law scholars, amici have a strong interest in the sound development of administrative law in the federal courts, and are submitting this brief because of the importance of the administrative law and statutory interpretation issues raised by the Middle District of Florida's interpretation and application of the major questions doctrine. Amici are well-positioned to provide expert insights that may assist the Court in evaluating the district court's interpretation of the doctrine and the parties' arguments regarding its applicability in this case.