"Section 1733 of the Federal Land Policy and Management Act (FLPMA) confers expansive criminal lawmaking power on the Secretary of the Interior in violation of the Constitution, allowing the Secretary, acting through the Bureau of Land Management (BLM), to create a criminal code applicable over a significant part of the country and a majority of the state of Nevada."
"This case is the ideal vehicle for revitalizing the nondelegation doctrine because the OSH Act represents, arguably, the broadest delegation by Congress to the Executive Branch since the NIRA."
"This Court should enforce the Constitution’s structural guarantees of liberty and hold that the executive branch is precluded from acting as investigator, prosecutor, judge, jury, and appellate court in cases involving the core private rights of individuals and businesses. If the NLRB has a case against SpaceX, it can make that case in a court of law before a jury."