The first line of Kristin Hickman and Matthew Krueger’s article announcing that “Skidmore deference is back” brings to my mind those awful horror villains of the 1980s—like Jason from the Friday the 13th movies or Chucky from the Child’s Play series—who repeatedly returned to terrorize. The fact that the revival of Skidmore triggers the memory of these bloodthirsty and unstoppable-against-all-odds villains will be no surprise to most administrative law practitioners and scholars (not to mention law students). Like Jason and Chucky, Skidmore is not just scary; it is a very messy business.


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