The following excerpt is from Municipality of Anchorage v. U.S., 980 F.2d 1320 (9th Cir. 1992):
In Mada-Luna v. Fitzpatrick, 813 F.2d 1006 (9th Cir.1987), this court considered the question of what distinguishes a substantive rule from a general policy statement. The court stated:
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