@techreport{8t99n6,
  author = {Gilly, Travis},
  title = {{The Partnership Pretext: Statutory Vesting, the Administrative Procedure Act, and Disability Rights Enforcement}},
  institution = {Real Safety AI Foundation},
  type = {Working Paper},
  year = {2026},
  month = jun,
  note = {Version 0.3},
  url = {https://realsafetyai.org/research/8t99n6/},
  keywords = {Administrative Procedure Act, ultra vires, 20 U.S.C. 1402, Department of Education Organization Act, Office for Civil Rights, pretext, Department of Commerce v. New York, Village of Arlington Heights, Section 504, ADA Title II, IDEA}
}