Tozzi v. HHS

To: ABA Conference Group

I am pleased to participate in the upcoming ABA  conference which will discuss “ex parte” contacts.

Please note I have on prior occasions offered my opinion on an interpretation of a judicial decision, in particular  Sierra Club v. Costle.

Individuals  who know  I am  not an attorney have made inquiries   regarding my credentials to make such interpretations.

Recognizing  I could  not  correct, at least in the short run,  the  deficiencies in my DNA that prevented me from being  an attorney I decided that  the next best thing was to become  a plaintiff  and  winning —-at least on the issue of the reviewability of a  standalone   report.

I am  providing  the following material in reference to the above.


Jim  Tozzi


Tozzi v. HHS  is a precursor to the Data Quality Act which allowed outside parties to challenge theretofore non-challengeable scientific determinations made by regulatory agencies.

Tozzi v. HHS is an important recognition that agency action short of actual regulation can have ramifications sufficient to justify judicial review.”


Judicial Citations:

Tozzi, Jim J. v. HHS, 271 F.3d 301 (D.C. Cir. 2001)   as of  08.06.2014

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