The expansion of expedited removal should have gone through Notice and Comment before being implemented.
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Get it written →Write 3-5 sentences 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?
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