United States v. Anthony Ross

I join in full that portion of the opinion holding that the Attorney General lacked good cause to forgo notice and comment when issuing the Interim Rule, particularly given that he waited 217 days after the Sex Offender Registration and Notification Act (“SORNA”), 42 U.S.C. § 16901 et seq., took effect to put that rule out. See Applicability of the Sex Offender Registration and Notification Act, 72 Fed. Reg. 8894-01 (Feb. 28, 2007) (codified at 28 C.F.R. pt. 72). I also agree that the error does not meet our high standard for harmlessness in this particular Administrative Procedure Act…