At the *very* least you should be following the administrative rules act (requiring you to solicit 45 days for comments by effected parties) before making such a dramatic change in policy.
Courts absolutely love striking down EOs (of both Dems and Reps Admins) when they should have been following the administrative rules act.
You can file an APA lawsuit about anything. Nobody really calls APA violations “illegal.” It’s a “show your work” and “don’t be drunk or crazy” procedural law.
At the *very* least you should be following the administrative rules act (requiring you to solicit 45 days for comments by effected parties) before making such a dramatic change in policy.
Courts absolutely love striking down EOs (of both Dems and Reps Admins) when they should have been following the administrative rules act.