In 1975, a young administrative law scholar, Richard Stewart, published “The Reformation of American Administrative Law” in the Harvard Law Review.1 His 150-page narrative is a grand portrayal of a dramatic shift in the nature of administrative law. According to this narrative, the traditional understanding of administrative law, which Stewart called the “transmission belt model,”2 was “essentially a negative instrument for checking government power,”3 aimed at the management of “the problem of discretion.”4 Harkening back to the idea that the New Dealers saw expertise as a solution for this discretion, Stewart allowed that expertise “could plausibly by advocated as a solution to the problem of discretion,” but only if the “agency’s goal could be realized through the knowledge that comes from specialized experience,”5 which Stewart doubted was possible.6