Washington, D.C.; September 8, 2025: Pacific Legal Foundation today announced the launch of the Nondelegation Project, a groundbreaking new tool that uses artificial intelligence to trace every federal regulation back to the law that supposedly authorizes it.

The tool—which was developed by Patrick McLaughlin, a visiting research fellow at PLF—reveals whether Congress granted agencies broad, open-ended powers or gave them narrow, specific instructions. That distinction is crucial in the wake of the Supreme Court’s recent decisions in West Virginia v. EPA, which developed the major questions doctrine, and Loper Bright, which restored meaningful judicial review of agency power. By mapping the legal foundation of each rule, the Nondelegation Project highlights which regulations may now be vulnerable to challenge.

An accompanying explainer on the Nondelegation Project identifies the agencies with the highest number of general delegations:

  1. Federal Energy Regulatory Commission (3,309)
  2. Environmental Protection Agency (2,752)
  3. Agricultural Marketing Service (1,284)
  4. Food and Drug Administration (1,155)
  5. Department of Justice (661); Food Safety and Inspection Service (661)

“Americans deserve a government where Congress writes laws, not unelected bureaucrats,” said Patrick McLaughlin. “This tool sheds light on the extent to which agencies have relied on vague or sweeping grants of authority to expand their reach. It provides lawyers, lawmakers, and the public with a new way to hold the administrative state accountable.”

Pacific Legal Foundation took on the project because PLF is committed to ending unconstitutional delegations of legislative power. By empowering the public with data and transparency, PLF is advancing its mission to restore the Constitution’s separation of powers and defend individual liberty.

Visit www.nondelegationproject.org to explore the tool.

Documents

Policy Explainer about the Nondelegation Project
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About Pacific Legal Foundation

Pacific Legal Foundation is a national nonprofit law firm that defends Americans threatened by government overreach and abuse. Since our founding in 1973, we challenge the government when it violates individual liberty and constitutional rights. With active cases in 34 states plus Washington, D.C., PLF represents clients in state and federal courts, with 18 wins of 20 cases litigated at the U.S. Supreme Court.

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