Document Type


Publication Date



When it comes to understanding the political dynamics of agency rulemaking, the place to start is Rachel Potter’s book Bending the Rules: Procedural Politicking in the Bureaucracy, about which the Yale Journal on Regulation published a blog symposium in 2019. Through a mix of qualitative and quantitative methods, Potter explores how agency officials—both career civil servants and political appointees—play a role in the rulemaking process and leverage procedural rules to help advance their preferred policy outcomes.


All Jotwell content is available under a Creative Commons Attribution-Noncommercial-Share Alike 3.0 License. The Attribution-Noncommercial Share Alike License allows others to use and modify Jotwell materials for noncommercial purposes, as long as they acknowledge Jotwell and the author of the contribution as the source of their material. This article was originally published as Christopher Walker, Outsourcing Agency Rulemaking, JOTWELL (February 14, 2023) (reviewing Bridget C.E. Dooling & Rachel Augustine Potter, Regulatory Body Shops, Duke L.J. (forthcoming), draft available at SSRN. ),