After a 12-year investigation and cycle for issues concerning food labeling with literally almost 60,000 pages and documents, the commissioner of the FDA who had overseen the entire proceeding resigned. Four months later a new Commissioner was appointed, and within 12 days, he signed 14 final regulations, 13 proposed regulations, and 6 miscellaneous notices. On the 13th day, he signed the rules in question. Ps petitioned for review contending it was impossible for the Commissioner to have reviewed the objections prior to promulgating the rules.

This section contains the nature of the case and procedural background.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.