LOKEN, Circuit Judge.
The Randolph-Sheppard Vending Stand Act, 20 U.S.C. §§ 107-107f (the "Act"), creates a complex federal-state administrative regime intended to give blind persons preferential opportunity to operate vending facilities on federal, state, and private premises. The Secretary of Education oversees implementation of the Act, but the day-to-day operations of the program, including licensing individual blind vendors and placing them in selected...
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