id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-2511	Slaughter, Anne	The Interpretive Rule Exemption: A Definitional Approach to Its Application	1982	30	.pdf	application/pdf	13917	637	55	[hereinafter cited as Lee Article], 23Professor Davis has always maintained that the legislative authority is the only distinguishing factor between interpretive rules and legislative rules. Although the court briefly mentioned the gray area where it is difficult to distinguish interpretive rules from legislative rules that interpret statutes, the court ignored this dilemma and held the agency action to be an interpretive rule ex- empt from notice and comment proceedings.31 The court claimed to 26 See, e.g., Eastern Ky. Welfare Rights Org.	cache/inlawrev-2511.pdf	txt/inlawrev-2511.txt