2026 Admin. Law Part 2 Spring 2026

Administrative Law Legal Research Pt. 2

page 14 (3/19 content)

Professor Golsby ALR Spring 2026

Today’s Class

ADJUDICATIONS, RULINGS, DECISIONS

OTHER AGENCY DOCS

Lil bit of STATE Admin. Law

Administrative Decisions/Rulings

Opinions of an administrative law judge (“ALJ”) – formal adjudicative process w ‘sides’ of some kind.

• Most of the time not actually binding on later hearings, but strong indicator of how agency would behave in similar circumstances.
• May be appealed to higher authority, then review of a final agency decision can be brought to federal court.

Advisory opinions/rulings made by Admin. Judge or officer in an agency –

• Agency-issued advice/clarification to people or businesses who sought info on how policies might apply to a particular situation.
• NO PRECEDENTIAL VALUE but is considered a strong indicator of how an agency will interpret its policies.

BUT ALSO… Agency action can be reviewed in federal court a few ways-

• A regulations may be challenged for being:
• Too broad
• Too narrow
• Pointless
• In excess of the powers delegated to the agency
• Completely absent (if congress told the agency to write rules about something and they did not)
• Otherwise unconstitutional
• An agency hearing may turn into a federal court case if there has been a final appeal within the agency and they aggrieved party wants to appeal again.

ALJ Decisions

• Hearings are usually presided by admin. law judges.
• Only about 15 agencies publish ALJ opinions in some consistent way, you can see which ones and their respective reporters in T1.2 of the Bluebook. A few examples:

• USDA
• Decisions – Agriculture Decisions (Agric. Dec.)
• Directives – USDA subagencies do this a lot so there are multiple sources, see the table.
• EEOC
• Cite by using decisions number, no reporter but there are special ways to cite.
• EPA
• Decisions – Environmental Administrative Decisions (E.A.D.)

Opinions/Rulings

Certain agencies use these more than others, and in some types of law these sources are vital.

• Example: Tax law practice is HEAVY with what’s called “Private Letter Rulings.” These are binding on (If you get into tax, I highly suggest a separate research tutorial)
• Non-precedential, interpretive analysis of how IRS would treat a person or business in a given situation. Person/business asks for it.
• Indicates how the IRS would interpret a situation that is highly similar.
• Example 2: The D.O.J. (as the Fed. Gov’t’s ‘law firm’) provides Attorney General Opinions
• Advisory, non-binding, but have a lot of persuasive authority.
• The “hard part” – figuring out what kinds of important sources are available on a topic or through an agency.
• Check out the agency’s website
• Look for a secondary or practice-oriented source for your area of law or for the topic

ALJ Opinions in Westlaw – practice area

ALJ Opinions in Westlaw – Practice Area

Notice sometimes an agency will have subagencies, each with their own type of decisions.

• The Admin. Appeals Office Decisions are those made in a quasi-judicial capacity.
• The Policy & Procedure Memoranda are advisory.

ALJ Opinions in Westlaw – Across Agency Search

ALJ Opinions in Westlaw – Citing References

The same stuff in Lexis… (from practice area)

Finding Agency Decisions Elsewhere – tips and tricks

Here is what I will call an ‘easy’ agency to research– the FTC. Go to https://www.ftc.gov/ to follow along.

Notes on finding case law…

You have done this before! (1) Pull up statute or reg. (2) Citing references>Cases Tip – a case reviewing the final decision of an ALJ will likely refer to the regulations that apply to hearings in that agency.

Notes on finding case law…

You can also search within cases for the name of a federal agency and some key words.

CALI is back up!

Other Agency Docs

• Manuals, practical guidance, data (big one for some people!), and more.
• Not law, but important because they are often the agency speaking about what it ‘thinks’ about certain issues or how it expects people to obey in practice.
• The availability and importance of this ‘extra’ stuff varies widely across agencies, so let’s just see what’s available from a few popular agencies.
• DOL - OSHA Publications
• EPA - Guidance Documents
• DOJ - Guidance docs, forms, Justice Manual

State Admin - Generally

• For the most part, state administrative law sources are analogous to federal. States usually have a number of agencies, many of which reflect their federal counterparts.

Massachusetts Admin/Regulatory Research

Click here for a great library guide on important Mass. Admin. Resources.

• In a nutshell:
• Mass. Admin. Register (Costs money)
• Mass. Code of Regulations (Free)
• Adminstrative Appeals:
• https://www.mass.gov/administrative-appeals-process

Directory of agencies in MA: https://www.mass.gov/collections/massachusetts-state-organization-directory

Directory of agencies in WI: https://www.wisconsin.gov/pages/allagencies.aspx

Directory of agencies in NY: https://www.ny.gov/agencies

The End