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Administrative Procedure Act and New York State law. Administrative law, as laid down by the Supreme Court of India, has also recognized two more grounds of judicial review which were recognized but not applied by English Courts, namely legitimate expectation and proportionality. The actions of executive agencies and independent agencies are the main focus of American administrative law. In response to the rapid creation of new independent agencies in the early twentieth century see discussion below, Congress enacted the Administrative Procedure Act APA in 1946. Many of the independent agencies operate as miniature versions of the tripartite federal government, with the authority to "legislate" through rulemaking; see Federal Register and Code of Federal Regulations, "adjudicate" through administrative hearings, and to "execute" administrative goals through agency enforcement personnel. Because the United States Constitution sets no limits on this tripartite authority of administrative agencies, Congress enacted the APA to establish fair administrative law procedures to comply with the constitutional requirements of due process.

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See United States v. Jackson, 978 F. 2d 903, 915 5th Cir. 1992, cert. denied, 508 U. S. 105 1991. The Court recognized "a compelling interest in compensating victims from the fruits of the crime, but little if any interest in limiting such compensation to the proceeds of the wrongdoer's speech about the crime," Id. 502 U. S. at 120 21.