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How do bureaucrats of underrepresented and marginalized racial groups initiate racial policy change? Existing policy theories and political-process models do not accurately portray the policymaking process of Black American bureaucrats. In this paper, I propose a theory that encapsulates how Black federal administrators initiate policy change. I use the case of the Black Cabinet, a group of Black civil servants who served in the federal bureaucracy from 1933-1945, to provide a model for racial policy change. Through an archival analysis of Black Cabinet members’ activism against discriminatory practices within various departments of the federal bureaucracy, I examine how the Black Cabinet participated in the policymaking process while navigating through limited political venues and restrictive institutional channels. I highlight the use of social networks, news media, and institutional and political loopholes as essential tools for bureaucrats in creating policymaking pathways.