Students in Penn State Dickinson Law ‘Employment Law Seminar’ submit comments to federal agencies

CARLISLE, Pa.—Students in Professor Samantha Prince’s “Employment Law Seminar” recently learned a hands-on lesson in advocacy. To build on lessons learned in class, she offered students the choice of presenting a case study or selecting a federal agency request for comment on rulemaking or policy and submitting a letter.

“Nearly half of the class chose to write to a federal agency on an employment law-related topic. Each response letter was well-researched and written persuasively, with a suggestion for the agency,” said Prince.

Using digital assets in the digital finance landscape

Ariana M. Bignotti ’27 and Alex Cappelinni ’27 responded to the U.S. Department of the Treasury's request for comment on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS Act). “I was interested in exploring this act because of its legal implications in the digital finance realm,” said Bignotti. “As digital assets continue to become more widespread in our society, I think it is critical that they are used safely, particularly within the evolving online financial market.”

Their comment focused on how certain artificial intelligence (AI) methods have been used by traditional financial institutions to detect and mitigate illicit activity and how these tools can be helpful for anti-money laundering (AML) compliance in the digital finance space. “We ultimately recommended that the Treasury promote adaptive learning AI systems that integrate both behavioral analytics and blockchain pattern analysis to identify suspicious activity within the digital finance space, which would help strengthen AML initiatives,” said Bignotti.

“This was a great learning experience. You learn about legislative comments in your first-year research and writing classes, but sitting down and writing one was much more informative of the whole process,” said Cappelinni.

Limiting employer responsibility in ‘inherently risky’ professions

Colton Mitchell ’26 and Natalie J. Cestone ’26 submitted a public comment to the Occupational Safety and Health Administration (OSHA) in response to its proposed interpretation of the General Duty Clause of the Occupational Safety and Health (OSH) Act.

“I wanted to comment on this proposal because it raised questions of statutory interpretation, agency authority, and workplace protection, areas I’ve focused on in my coursework. The proposal also presented a clear tension between the text and purpose of the OSH Act and the agency’s attempt to narrow longstanding enforcement principles,” said Mitchell.

The students challenged OSHA’s effort to exclude certain high-risk professions from federal safety enforcement, arguing that this shift would undermine 50 years of worker-protection law. Using congressional intent, Supreme Court precedent, and OSHA’s own enforcement history, they explained why the General Duty Clause should remain a universal baseline for workplace safety.

“This was a powerful learning experience because it took what we study in class and made it feel real,” said Cestone. “Instead of just reading about administrative law, we were actively participating in the regulatory process and contributing to a live policy debate. Knowing that our work could potentially influence how a federal agency approaches workplace safety made the project feel meaningful and impactful, and it reminded us why we chose to go to law school in the first place.”

Removing COVID-19 Emergency Temporary Standard recordkeeping and reporting provisions

Dinah da Nobrega Araujo ’26 and Madison Grace Cain ’26 submitted an anonymous comment on OSHA’s proposed rule to remove the COVID-19 Emergency Temporary Standard’s remaining recordkeeping and reporting provisions. “We chose this issue because it sits at the intersection of health law, administrative law, and worker protection, areas we share an interest in,” said Cain.

Their comment requested that OSHA revise the COVID-19 recordkeeping and reporting requirements instead of completely removing them. “The recommendation is to integrate a streamlined COVID-19 log into a broader, digitally enhanced infectious disease standard under 29 C.F.R. Part 1904. This approach would reduce administrative burdens while preserving the critical surveillance infrastructure necessary to protect workers in health care and other high-risk settings from persistent and future infectious threats,” said da Nobrega Araujo.

“This was a valuable learning experience because it required us to apply statutory authority, agency reasoning, and policy analysis to a real federal proposal, helping us better understand how legal advocacy influences administrative action,” said Cain.

Prince was pleased that so many students took advantage of the opportunity. “I emphasize in class that students become experts in certain topics while at Penn State Dickinson Law and have an obligation to share their expertise with the public. It is gratifying that so many students were interested in sharing their knowledge and providing suggestions to the government,” said Prince.