| 21. | The recess appointment was required because of a hold on Eisen s nomination.
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| 22. | On March 24, the Legislature rejected the recess appointment of Joseph Ellicott.
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| 23. | Adjusts description of recess appointment in graf 11.
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| 24. | Presidents since George Washington have used recess appointments in the gaps between congressional sessions.
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| 25. | No president had used the recess appointment to fill a judicial opening since 1980.
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| 26. | Regardless, the Recess Appointments Clause is not designed to overcome serious institutional friction.
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| 27. | Letts initially received a recess appointment to a seat vacated by Wendell Philips Stafford.
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| 28. | Leichter began his service in August 2000 with a recess appointment from the President.
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| 29. | This was the first time that the Senate had rejected a presidential recess appointment.
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| 30. | President Obama initially gave Eisen a recess appointment.
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