Bijal Shah (Arizona State University (ASU) – Sandra Day O'Connor College of Law) has posted Toward A Critical Theory of Administrative Law (Yale Journal on Regulation, Notice & Comment, 2020) on SSRN. Here is the abstract:
This contribution to a symposium on "Racism in Administrative Law" suggests that administrative law is missing a robust tradition of critical legal studies: https://www.yalejreg.com/nc/toward-a-critical-theory-of-administrative-law-by-bijal-shah/ (adapted for the American Bar Association, Administrative & Regulatory Law News (Summer 2020)).