Neomi Jehangir Rao

Neomi Jehangir Rao (born 1973) is an American jurist and legal scholar who has served as an active judge on the United States Court of Appeals for the District of Columbia Circuit since 2019. Appointed by President Donald Trump, she previously led the Office of Information and Regulatory Affairs within the Office of Management and Budget and held a tenured faculty position at George Mason University’s law school, now known as the Antonin Scalia Law School. Her career spans clerkships on both an appellate court and the Supreme Court, private practice in international arbitration, and extensive involvement in administrative‑law organizations.

Early life and legal career

Rao was born in Detroit in 1973 to Zerin and Jehangir Narioshang Rao, physicians who emigrated from India a year earlier. The family settled in the affluent suburb of Bloomfield Hills, Michigan, where she attended Detroit Country Day School, graduating in 1991. After high school she pursued an interdisciplinary undergraduate program at Yale University, concentrating on ethics, politics, economics and philosophy; she earned a Bachelor of Arts cum laude in 1995. During the year following her graduation Rao worked as a reporter for *The Weekly Standard*, gaining experience in political journalism before entering law school.

She enrolled at the University of Chicago Law School, where she distinguished herself academically, graduating with high honors and membership in the Order of the Coif in 1999. While a student she served as comment editor of the University of Chicago Law Review and as executive editor for a symposium issue of the *Harvard Journal of Law and Public Policy*. Upon completing her Juris Doctor, Rao embarked on a series of prestigious clerkships: first with Judge J. Harvie Wilkinson III of the Fourth Circuit (1999‑2000) and subsequently as legal counsel to the Senate Judiciary Committee (2000‑2001). She then clerked for Justice Clarence Thomas of the United States Supreme Court during the 2001‑2002 term.

Following her Supreme Court clerkship Rao entered private practice in London with Clifford Chance, focusing on public international law and arbitration. In 2005 she returned to Washington, D.C., to serve as an associate counsel within the White House Counsel’s Office under President George W. Bush. The following year she joined the faculty of George Mason University School of Law, where she progressed from assistant professor to tenured full professor in 2012. While at Mason, Rao founded the Center for the Study of the Administrative State in 2015, reflecting her scholarly interest in regulatory governance.

Rao’s professional affiliations include membership in the Administrative Conference of the United States and a leadership role on the governing council of the American Bar Association’s Section of Administrative Law and Regulatory Practice, where she co‑chairs the regulatory policy committee. She is also a member of the Federalist Society, an organization devoted to conservative and libertarian legal perspectives.

Federal appellate service

President Donald Trump nominated Rao on April 7 2017 to become administrator of the Office of Information and Regulatory Affairs (OIRA), the office within the Office of Management and Budget that reviews federal regulations. The Senate confirmed her to that post on July 10 2017, and she served as OIRA’s head until her judicial appointment.

The president announced his intent to nominate Rao to the D.C. Circuit on November 13 2018, intending for her to fill the vacancy created by Judge Brett Kavanaugh’s elevation to the Supreme Court. The nomination was transmitted to the Senate that day. After the 115th Congress adjourned, the nomination was returned under Senate Rule XXXI, Paragraph 6, on January 3 2019 and subsequently resubmitted on January 23 2019.

During her confirmation hearing before the Senate Judiciary Committee on February 5 2019, Rao addressed questions concerning earlier writings on topics such as race, sexual assault, feminism, multiculturalism and disability rights. She affirmed that victims of violent crimes should not be blamed and emphasized personal responsibility for perpetrators. The committee advanced her nomination by a 12‑10 vote on February 28 2019.

The full Senate invoked cloture on Rao’s nomination on March 12 2019 with a vote of 53‑46, and she was confirmed the following day by an identical margin. She received her judicial commission on March 18 2019 and assumed active service on the United States Court of Appeals for the District of Columbia Circuit, occupying seat CADC1303.

Since joining the bench, Rao has participated in panels addressing a range of administrative‑law issues. Notably, in October 2019 she authored a dissenting opinion in *Trump v. Mazars*, a 2‑1 decision affirming a district court’s order that upheld a congressional subpoena for President Trump’s financial records held by the accounting firm Mazars. In her dissent, Rao expressed concerns about the scope of congressional investigative authority.

Jurisprudence and legacy

Rao’s judicial work reflects the administrative‑law expertise cultivated throughout her academic and executive‑branch career. Her opinions often engage with questions concerning the limits of agency discretion, the procedural requirements for regulatory review, and the balance between legislative oversight and executive authority. The *Mazars* dissent illustrates her willingness to scrutinize congressional subpoenas that intersect with presidential interests, emphasizing a careful reading of statutory and constitutional constraints.

Beyond specific cases, Rao’s broader impact on the D.C. Circuit can be seen in her contributions to the development of administrative‑law doctrine at a court frequently called “the second most powerful” appellate tribunal in the nation. Her background as an OIRA administrator provides a practical perspective on how agencies formulate and justify regulations, informing her analytical approach when evaluating agency actions before the court.

Rao’s scholarly activities continue to shape discussions about regulatory reform. The Center for the Study of the Administrative State, which she founded while at George Mason, remains a venue for research and dialogue on the structure and function of the administrative state. Her involvement with the Administrative Conference and the ABA’s regulatory‑policy committee further underscores her ongoing engagement with policy‑making processes outside the judiciary.

While Rao’s confirmation process attracted attention to past writings on social issues, she has consistently framed her judicial philosophy around adherence to precedent, procedural fairness, and a measured interpretation of statutory text. Her statements during the confirmation hearings indicated an intention to follow established standards for recusal and to consult colleagues when potential conflicts arise, reflecting a commitment to maintaining the integrity of the court.

In sum, Neomi J. Rao’s career bridges academia, executive administration, private practice, and federal adjudication. Appointed to the D.C. Circuit by President Trump in 2019, she brings extensive experience in administrative law to a court that plays a pivotal role in shaping national regulatory policy. Her opinions and scholarly contributions continue to influence debates over the scope of agency authority, the proper conduct of congressional oversight, and the evolving contours of the United States’ administrative state.