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Nondelegation doctrine cases follow a predictable pattern. Every few years, a court of appeals invokes the doctrine to strike down a federal statute. 1 The Supreme Court inevitably grants certiorari and overturns the appellate decision, holding that the statute is a constitutional delegation of legislative authority. 2 Without fail, the Supreme Court ruling sparks a heated debate among constitutional law scholars. Some support the decision-praising the Court for driving another nail into the coffin of the nondelegation doctrine. 3 Others oppose the decision-lamenting the Court's failure to revive the doctrine and use it to rein in the ever-expanding administrative state. 4 Despite their intense disagreement over what role the nondelegation doctrine ought to play in today's legal system, both groups of scholars agree on the role that the doctrine has played throughout US history. Specifically, they all endorse the narrative that …