Article Title

Commentary: An Update on Federal Agency Recognition of Grantee Due Process

Publication Title

Washington University Law Quarterly


This Article focuses on two major advances that the larger federal grantor agencies have made toward full recognition of grantees' due process rights. First, these agencies increasingly recognize that there are a variety of grantor determinations in addition to termination (a rarely used sanction) that can adversely affect grantees and should be made appealable at the agency level. Second, despite the fact that a grantee's right to due process protections with respect to nontermination decisions still is being debated in the courts, these larger grantors have designed and implemented relatively sophisticated and protective appeal mechanisms.