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Bump Stock Rule Puts Constitution In The Crosshairs
Speaker of the House Nancy Pelosi recently warned Republicans that if a GOP president can declare a national emergency over a wall on the southern border, the next Democrat president could declare one over gun violence. Her threat envisioned future gun control actions without Congress. But that’s already happening—and it has made a shambles of…
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Comments in Response to the U.S. Sentencing Commission: Proposed Amendment for Sentencing Guidelines
In the News
Sentencing Guidelines for the Court; Proposed Amendment 2018-27505 Amending § 4B1.2 NCLA applauds the Sentencing Commission’s desire to rectify serious issues pertaining to the Guidelines. NCLA does not take a position regarding the appropriate definition of the terms “crime of violence” or “controlled substance offense” or whether a categorical approach should be utilized. Id. at 65401.…
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Comments in Response to the Department of Education's Proposed Rule: Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance
In the News
Re: Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance, Docket Number ED-2018-OCR-0064 NCLA sincerely appreciates this opportunity to comment and express its concerns about the Proposed Rule. NCLA abhors unequal treatment on the basis of sex, particularly when it involves sexual harassment or assault. NCLA likewise laments the…
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Petition for Rulemaking: Promulgate Regulations Prohibiting the Issuance, Reliance On or Defense of Improper Agency Guidance
In the News
Re: Petition for Rulemaking to Promulgate Regulations Prohibiting the Issuance, Reliance on, or Defense of Improper Agency Guidance As the petition sets out in detail, NCLA asks DOT to cease its ad hoc promulgation of guidance by which DOT or the agencies under its auspices seek to bind private parties with the force of law. By…
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Comments in Response to HHS, CMS: Regulation to Require Drug Pricing Transparency
In the News
Re: Medicare and Medicaid Programs; Regulation to Require Drug Pricing Transparency Proposed Rule CMS-4187-P The Drug Pricing Rule is fatally flawed in two principal ways. First, CMS lacks the statutory authority to regulate the subject matter of the proposed Rule, pharmaceutical market efficiency. Second, even if CMS has the authority to regulate the subject matter,…
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The Hill: The SEC should listen to Sen. Cotton
In the News
Originally published in The Hill on December 17, 2019 On Tuesday Sen. Tom Cotton (R-Ark.) asked tough questions to the chairman of the Securities and Exchange Commission (SEC), Jay Clayton, during a banking committee hearing about an opaque form of regulation which has silenced Americans for far too long. The SEC lawlessly enacted the pernicious “gag rule” in 1972 without going…
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