Write 1 sentence 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?

Expansion of Expedited Removal

 

 

https://www.federalregister.gov/documents/2019/07/23/2019-15710/designating-aliens-for-expedited-removal

 

 

Write 1 sentence 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?