This post is the third contribution to Notice & Comment’s symposium on AI and the APA.

This symposium is for AI skeptics, AI believers, and everyone in between.

Last week, ProPublica reported that the United States Department of Transportation is planning to use Google Gemini, a large language model, to draft federal transportation regulations.

Even the shadow docket holds important lessons for litigants challenging the Trump administration’s funding actions and others.

Last month, Jeffrey Clark, the Acting Administrator of the Office of Information and Regulatory Affairs, issued yet another memorandum (M-25-36) describing how the Trump Administration intends to “streamlin[e] the review of deregulatory actions.”

The Trump administration is deploying a previously limited tactic to achieve its deregulatory goals: entering consent decrees—settlements between the parties that are entered as court orders—with private plaintiffs to wipe a challenged law or regulation from the books.