Federal agencies impose deadlines on themselves through their rulemaking powers, even though these regulatory deadlines carry costs for the agencies. When an agency misses its own regulatory deadline, citizens may sue the agency to force it to act. This presents two puzzles: Why do agencies self-impose internal deadlines? And why do courts enforce them?

This Note uses two theories to explain why agencies bind themselves through internal regulatory deadlines: Deadlines allow agencies to (1) entrench their policy preferences within and across presidential administrations, and (2) make credible commitments to enforce their regulations, which signals resolve to regulated parties and incentivizes them to comply without agency intervention.

This Note also provides the first account of what law applies in regulatory-deadline suits. Most courts have held that regulatory deadlines are mandatory and thus judicially enforceable. To reach this conclusion, courts have invoked the Accardi doctrine, which states that agencies must follow their own rules. But this Note argues that applying the Accardi doctrine in regulatory-deadline suits is unwarranted under Supreme Court precedent. It then revisits the source of the Accardi rule and offers a different doctrinal justification for enforcing regulatory deadlines. This Note concludes by exploring the normative stakes of enforcing internal regulatory deadlines against agencies.

* J.D. Candidate, Stanford Law School, 2023. Special thanks to Anne Joseph O’Connell for her invaluable feedback, guidance, and encouragement. I am also grateful to Ryan Snyder for sharing insightful comments. Finally, thank you to the hardworking and thoughtful editors of the Stanford Law Review, especially the SLR Board, Chico Payne, Coley Navarro, Maya Frost-Belansky, Priscilla Guo, Max Kennedy, Ben Mishkin, and Saj Sri-Kumar.