Schiller’s submission examines the recently emergent legal literature that focuses on the original intent of the APA. Ideologically diverse scholars are using this literature to support sometimes divergent visions of administrative law reform. He suggests that scholars on both sides of the APA originalism debate risk substituting “law office” histories of the Act for actual historical analysis. He then describes how legal history may not be able to provide APA originalists with the information they need. Finally, he suggests some fruitful areas of historical inquiry about the APA that may benefit APA originalists, and will certainly benefit historians who wish to create a more complete narrative of the emergence of administrative law during the first half of the twentieth century. Joanna Grisinger will provide commentary. THIS SESSION IS NOT ELIGIBLE FOR CLE CREDIT.