s rule is entitled to deference regardless of how it is characterized because it is “reasonably related to the purposes of the enabling legislation,” Thorpe, 393 U.S. at 280-81, and constitutes a “reasonable interpretation’ of the enacted text,’ Mayo, 131 S. Ct. at 714 (quoting Chevron, 467 U.S. at 844).

prior to Mayo, a long line of both non-NLRA and NLRA cases supported reading Section 6 in the manner suggested by the Board. Over forty years ago, in Thorpe v. Housing Authority,'® the Supreme Court found that the expansive grant of rulemaking authority in Section 8 of the Housing Act was sufficient to gr

2006) v.cccsseseesseensen Sys. v. Masterson Mktg., No. 11-CV-695, 2011 U.S. Dist. LEXIS 135216 (S.D. Cal. Nov. 23, 2011) eccessscseeseseseeeseeeeen Thorpe v. Housing Auth., 393 U.S. 268 (1969) 0. eeseeeccsesseeeeecees U.S. Bank Nat’l Ass’n v. Verizon Commce’ns, Inc., No. 10-CV-1842, 2011 U.S. Dist. LEX

(2d Cir. WESTLAW HOUSE_OVERSIGHT_023408 --- PAGE BREAK --- In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) 1997) (quoting Thorpe v. Housing Auth., 393 U.S. 268, 281 (1969)). Here, that law has been established by Doe, an intervening decision, and Doe’s application to the Sovere