In this article, Adam Feinberg discusses the state of deepwater drilling in the Gulf of Mexico after the 2010 oil spill and the federal government’s efforts to impose a moratorium on drilling. The government initially imposed a moratorium on nearly all deepwater drilling in the Gulf of Mexico. After that moratorium was struck down by a federal court, the government defiantly re-imposed the same flawed moratorium. It then denied the court an opportunity to review the second moratorium by replacing it with new drilling requirements that were both insufficiently articulated and issued in violation of the Administrative Procedure Act, resulting in another four-and-a-half months of a de facto moratorium. This article addresses the government's failure to follow the rule of law.