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rights primarily based on involvement with a prior regime. Best follow lustration methods make particular person determinations, do not deal with the entire group as black and white, and set up an administrative system to adjudicate claims for exemption in an impartial and reasonably expeditious manner. The APA requires separation of the agency’s adversarial enforcement staff from its adjudicative decisionmakers as a matter of personnel, oversight, and communications. See U.S.C. §5 providing employees engaged in adversarial investigation or prosecution might not “take part or advise in the determination, recommended choice, or company evaluate . except as witness or Amazing God happy easter day bunny all over printed hawaiian shirt counsel in public proceedings”; id. §5 stating hearing officers “could not consult a person or get together on a fact in concern, unless on discover and alternative for all events to take part”. Section5 also includes a “command influence rule,” which prohibits company adjudicators from being “accountable to or topic to the supervision or path of an worker engage . . . in investigative or prosecuting features for an agency.” Id. §5 But the APA does not mandate this separation for agency heads, who may hear appeals from initial adjudicators and are usually vested with the powers of initial decisionmakers. See id. §5 “This subsection doesn’t apply .
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