The pro forma session strategy simply takes advantage of the constitutional constraints that presidents require congressional recesses
in order to make recess appointments.
legislative breaks--intersession recesses
, which occur between the two
That distinction protects a number of historical appointments made during recesses
, and while the appointments in this case were made during the recess that takes places during Christmas, because of the "pro forma" sessions that took place during that year, the recesses
were not long enough to warrant the use of recess appointment power.
Second, what types of recesses
are comprehended by the Clause?
But it concluded that "the most natural reading" of the phrase "next session" limited the president's appointment power to intersession recesses
"the Recess" means only intersession recesses
. (14) A May 16,
Perhaps it was partly in compromise, partly in acknowledgement of my arguments that Patricia began to abandon the soap half-way between the recesses
Offices face south and west, so the deep recesses
and stone shutters offer much needed protection against heat and glare; on this facade the external wall is around 1m thick to accommodate the shutters.
The layer has a number of small open recesses
in both surfaces of the absorbent layer and extends toward an inner area of the absorbent layer.
In 1789 and for ten sessions thereafter, intersession recesses
of Congress averaged seven months in length.
are in the aggregate of lesser width than the wood members within which they are secured.