Senator Carl Levin, RIP

We are saddened to hear of the passing of Senator Levin. He publicized the quote:  “Tozzi does not leave fingerprints”. He was a constant critic of OMB’s early regulatory review process. He frequently used that quote when he introduced regulatory reform legislation.  That said, he was a fair and open minded Senator. He was respectful in dealing with individuals who did not share his views and he never held a personal grudge.

If we only had more Senator Levin’s in the Senate!


Jim Tozzi

The Birth of a Legal Doctrine in the Administrative State

The birth of a legal doctrine often begins when an academician associated with the legal academy has an idea on how to improve the administrative state and publishes it in a journal; a colleague reads it and elaborates on its content. With the passage of time other academicians might endorse the concept.

In the meantime, the doctrine is fertilized by teaching it in law schools, the birthplace of judges who then occasionally endorse it in one of their subsequent legal proceedings which often establish a national precedent. Absent from participation in this endeavor is any consistent proactive procedural input from neither the Executive nor the Legislative Branches of government.

Man sentenced to 18 months after threatening to assassinate federal judge overseeing Michael Flynn case

Editor’s Note: We have appeared before Judge Sullivan; he has disagreed with us more than he has agreed with us. We found him to be a very balanced and thoughtful member of the judiciary. We know of very few issues that can compare with the threat to sitting members of the judiciary. A sound judiciary is the heart of a democracy. That said, we have been making these arguments, as have others, for years and little seems to be happening. Someone needs to take ownership of this issue; we nominate the new and very talented recently appointed Attorney General.


The Salaries of Government Contractors are Dwarfing Those of the Senior Executive Service

Scholars have written repeatedly about the contracting out of critical government programs to the private sector. One of the reasons for the huge drain of the most prized talent is salaries. The top pay of  a government contractor is $ 349,00. The top salary for a member of the Senior Executive Service (SES) is $ 204,000

CRE is of the opinion that the compensation of the most senior executives of the contracting community is considerably higher than $349,000 because of the result of partnership status. In any event kudos are due to those championing transparency in contractor salaries, in particular the OMB employees in charge of this matter.

The New FTC: Exhibit # 1 on the Need to Revamp Both Law School Curricula and the Regulation of Big Tech

07/19/2021    Advised Big Tech firms of the merits of a Self-Regulated Organization

07/16/2021    Revised Text of this Post

07/10/2021    Notification of public of related publications

  • Resurrection of CRE’s Recommendation for Regulating Big Tech
  • Wall Street Journal’s Insightful Background on the Biden Executive Order