Rachel Augustine Potter points out that more than 90 percent of American “laws” are developed and implemented by unelected bureaucrats, rather than through congressional legislation (p. 2). Because of the importance of this fact, many scholars, across many academic disciplines, have studied how political principals—Congress, the president, federal courts—may utilize their powers to control the bureaucracy’s policymaking behavior. One particularly influential idea from this literature argues that the design of administrative procedures to guide bureaucratic behavior is a powerful tool for doing just that.

In Bending the Rules, Potter develops a compelling argument highlighting how these procedural “controls” are precisely the means by which the bureaucracy can pursue its own goals through what she terms procedural politicking, or “using procedures in strategic ways so as to insulate policies that are at risk of political interventions and ensure that bureaucrat-preferred policies endure” (p. 6). With a focus on rulemaking, she illustrates how savvy bureaucrats—experts in how procedural choices impact overall outcomes— account for the nature of the broader political context when shepherding regulations through