The Additional H-2B Visa Numbers: Too Few, Too Late...And The "Irreparable Harm" Attestation is Ultra Vires

To understand what is wrong with the DHS/DOL Joint Temporary Final Rule adding 22,000 H-2B visas to the quota (6,000 reserved for nationals of the "Northern Triangle" countries of Honduras, El Salvador, and Guatemala), see my July 25, 2017 Law360 Expert Analysis - H-2B Visas and the Making of an Ultra Vires Regulation - (still fresh as a daisy, unfortunately) and David J. Bier's comments on Twitter.

- Dan Kowalski @dkbib on Twitter