national
labor
relations
board
sw
general
dba
southwest
ambulance
argued
november
decided
march
article
ii
constitution
requires
president
obtain
advice
consent
senate
appointing
officers
cl
given
provision
responsibilities
office
requiring
presidential
appointment
senate
confirmation
pas
office
may
go
unperformed
vacancy
arises
president
senate
promptly
agree
replacement
congress
accounted
reality
giving
president
limited
authority
appoint
acting
officials
temporarily
perform
functions
vacant
pas
office
without
first
obtaining
senate
approval
current
version
authorization
federal
vacancies
reform
act
fvra
section
fvra
permits
three
categories
government
officials
perform
acting
service
vacant
pas
office
subsection
prescribes
general
rule
vacancy
arises
pas
office
first
assistant
office
shall
perform
office
functions
duties
temporarily
acting
capacity
subsections
provide
notwithstanding
paragraph
president
may
direct
person
already
serving
another
pas
office
senior
employee
relevant
agency
serve
acting
capacity
instead
section
also
makes
certain
individuals
ineligible
acting
service
subsection
notwithstanding
subsection
person
may
serve
acting
officer
office
section
president
nominates
vacant
pas
office
period
preceding
vacancy
person
serve
position
first
assistant
office
served
position
less
days
general
counsel
national
labor
relations
board
nlrb
board
pas
office
june
vacancy
arose
office
president
directed
lafe
solomon
serve
acting
general
counsel
solomon
qualified
acting
service
subsection
fvra
senior
employee
nlrb
january
president
nominated
solomon
serve
nlrb
general
counsel
permanent
basis
senate
never
took
action
nomination
president
ultimately
withdrew
solomon
name
favor
new
candidate
senate
confirmed
october
throughout
entire
period
solomon
served
acting
general
counsel
nlrb
january
nlrb
regional
director
exercising
authority
solomon
behalf
issued
unfair
labor
practices
complaint
respondent
sw
general
administrative
law
judge
concluded
sw
general
committed
unfair
labor
practices
nlrb
agreed
sw
general
sought
review
appeals
district
columbia
circuit
arguing
complaint
invalid
subsection
fvra
solomon
perform
duties
general
counsel
nlrb
nominated
fill
position
nlrb
countered
subsection
applies
first
assistants
automatically
assume
acting
duties
subsection
acting
officers
like
solomon
serve
appeals
vacated
board
order
concluded
prohibition
acting
service
nominees
contained
subsection
applies
acting
officers
regardless
whether
serve
pursuant
subsection
result
solomon
became
ineligible
perform
duties
general
counsel
acting
capacity
president
nominated
fill
post
held
subsection
fvra
prevents
person
nominated
fill
vacant
pas
office
performing
duties
office
acting
capacity
prohibition
applies
anyone
performing
acting
service
fvra
limited
first
assistants
performing
acting
service
subsection
pp
text
fvra
requires
conclusion
pp
subsection
applies
person
prohibits
service
acting
officer
office
section
person
expansive
meaning
encompass
anyone
performs
acting
duties
fvra
see
pfizer
government
india
section
clarifies
subsection
applies
fvra
contains
specific
subsections
paragraphs
subsection
refers
contains
ways
person
may
become
acting
officer
rest
fvra
also
uses
pairing
person
section
encompass
anyone
serving
acting
officer
fvra
congress
readily
used
specific
language
intended
subsection
apply
first
assistants
acting
dependent
clause
beginning
subsection
otwithstanding
subsection
confirms
breadth
prohibition
acting
service
nominees
statutes
notwithstanding
clauses
show
one
provision
prevails
another
event
conflict
means
subsection
applies
even
conflicts
default
rule
first
assistants
shall
perform
acting
duties
pp
board
argues
phrase
notwithstanding
subsection
mention
congress
intend
prohibition
subsection
apply
people
serving
acting
officers
provisions
board
relies
interpretive
canon
expressio
unius
est
exclusio
alterius
expressing
one
item
associated
group
series
excludes
another
left
unmentioned
chevron
echazabal
internal
quotation
marks
omitted
interpretive
canon
applies
however
circumstances
support
sensible
inference
term
left
must
meant
excluded
notwithstanding
clause
naturally
give
rise
inference
shows
two
provisions
prevails
event
conflict
singling
one
conflict
generally
suggest
unaddressed
conflicts
resolved
opposite
manner
conflict
unique
former
uses
mandatory
language
first
assistant
shall
perform
acting
duties
latter
identifies
may
serve
acting
officer
notwithstanding
clause
clarifies
mandatory
language
subsection
prevail
subsection
event
conflict
subsections
lack
mandatory
language
natural
inference
congress
left
provisions
notwithstanding
clause
differ
subsection
implicitly
exempt
prohibition
subsection
moreover
subsection
specifies
shall
apply
certain
people
serving
first
assistant
applied
first
assistants
stating
limitation
superfluous
pp
text
clear
board
arguments
legislative
history
purpose
practice
need
considered
event
arguments
compelling
original
draft
fvra
contained
prohibition
nominees
serving
acting
officers
explicitly
limited
prohibition
first
assistants
board
argues
congress
revised
original
draft
made
changes
give
president
flexibility
appoint
acting
officers
intend
broaden
prohibition
nominees
performing
acting
service
glitch
argument
congress
change
prohibition
nominees
performing
acting
service
revising
clearly
apply
acting
officers
fact
certain
senators
stated
wanted
give
president
flexibility
appoint
acting
officials
mean
got
exactly
wanted
statement
one
sponsors
fvra
said
subsection
applies
first
assistants
overcome
clear
text
particularly
given
next
senator
speak
offered
contradictory
account
provision
board
also
argues
since
fvra
enacted
congress
objected
presidents
nominated
individuals
serving
acting
officers
subsection
office
legal
counsel
government
accountability
office
issued
guidance
construing
subsection
apply
first
assistants
relying
nlrb
noel
canning
board
contends
historical
practice
entitled
significant
weight
istorical
practice
grand
title
board
evidence
fvra
enacted
evidence
board
cites
significant
enough
warrant
conclusion
congress
failure
speak
implies
acquiesced
view
subsection
applies
first
assistants
contrast
decision
noel
canning
dealt
president
constitutional
authority
recess
appointments
clause
issue
attracted
intense
attention
presidents
attorneys
general
senate
dating
back
beginning
republic
pp
applying
fvra
case
straightforward
subsection
prohibited
solomon
continuing
service
acting
general
counsel
president
nominated
fill
position
permanently
president
appointed
another
person
serve
acting
officer
solomon
place
affirmed
roberts
delivered
opinion
kennedy
thomas
breyer
alito
kagan
joined
thomas
filed
concurring
opinion
sotomayor
filed
dissenting
opinion
ginsburg
joined
opinion
notice
opinion
subject
formal
revision
publication
preliminary
print
reports
readers
requested
notify
reporter
decisions
washington
typographical
formal
errors
order
corrections
may
made
preliminary
print
goes
press
national
labor
relations
board
petitioner
sw
general
dba
southwest
ambulance
writ
certiorari
appeals
district
columbia
circuit
march
chief
justice
roberts
delivered
opinion
article
ii
constitution
requires
president
obtain
advice
consent
senate
appointing
officers
cl
given
provision
responsibilities
office
requiring
presidential
appointment
senate
confirmation
known
pas
office
may
go
unperformed
vacancy
arises
president
senate
promptly
agree
replacement
congress
long
accounted
reality
authorizing
president
direct
certain
officials
temporarily
carry
duties
vacant
pas
office
acting
capacity
without
senate
confirmation
federal
vacancies
reform
act
fvra
et
latest
version
authorization
section
fvra
authorizes
three
classes
government
officials
become
acting
officers
general
rule
first
assistant
vacant
office
shall
become
acting
officer
president
may
override
default
rule
directing
either
person
serving
different
pas
office
senior
employee
within
relevant
agency
become
acting
officer
instead
fvra
however
prohibits
certain
persons
serving
acting
officers
president
nominated
fill
vacant
office
permanently
question
presented
whether
limitation
applies
first
assistants
automatically
assumed
acting
duties
whether
also
applies
pas
officers
senior
employees
serving
acting
officers
president
behest
hold
applies
three
categories
acting
officers
senate
advice
consent
power
critical
structural
safeguard
constitutional
scheme
edmond
framers
envisioned
excellent
check
upon
spirit
favoritism
president
guard
appointment
unfit
characters
family
connection
personal
attachment
view
popularity
federalist
rossiter
ed
hamilton
constitutional
process
presidential
appointment
senate
confirmation
however
take
time
president
may
promptly
settle
nominee
fill
office
senate
may
unable
unwilling
speedily
confirm
nominee
submitted
yet
neither
may
desire
see
duties
vacant
office
go
unperformed
interim
since
president
washington
first
term
congress
given
president
limited
authority
appoint
acting
officials
temporarily
perform
functions
vacant
pas
office
without
first
obtaining
senate
approval
earliest
statutes
authorized
appointment
person
persons
fill
specific
vacancies
departments
state
treasury
war
act
may
ch
stat
congress
first
allowed
acting
officers
serve
permanent
officeholder
resume
duties
successor
appointed
soon
imposed
limit
acting
service
act
ch
stat
congress
revisited
issue
ultimately
passing
vacancies
act
vacancies
act
expanded
number
pas
offices
president
fill
acting
officers
act
july
ch
stat
see
also
act
ch
stat
expansion
came
new
constraints
authority
appoint
person
persons
acting
officer
gave
way
default
rule
first
sole
assistant
shall
perform
function
exception
allowing
president
instead
fill
post
person
already
serving
pas
office
stat
rather
six
months
acting
service
vacancies
act
generally
authorized
ten
days
ibid
narrow
window
acting
service
later
lengthened
days
act
ch
stat
interbranch
conflict
arose
vacancies
act
department
justice
took
position
many
instances
head
executive
agency
independent
authority
apart
vacancies
act
temporarily
fill
vacant
offices
comptroller
general
disagreed
arguing
act
exclusive
authority
temporarily
filling
vacancies
executive
agencies
see
rosenberg
congressional
research
service
report
congress
new
vacancies
act
congress
acts
protect
senate
confirmation
prerogative
rosenberg
congress
amended
vacancies
act
clarify
applies
agencies
time
lengthening
term
permissible
acting
service
days
tolling
period
nomination
pending
see
presidential
transitions
effectiveness
act
stat
tensions
ease
approximately
percent
pas
offices
executive
agencies
occupied
temporary
designees
served
beyond
limitation
period
without
presidential
submissions
nominations
rosenberg
acting
officers
filled
positions
sometimes
obvious
contravention
senate
wishes
one
instance
brought
outside
government
serve
acting
assistant
attorney
general
civil
rights
division
justice
department
immediately
senate
refused
confirm
office
ibid
see
rosenberg
congressional
research
service
validity
designation
bill
lann
lee
acting
assistant
attorney
general
civil
rights
perceiving
threat
senate
advice
consent
power
see
rosenberg
congress
acted
replaced
vacancies
act
fvra
section
fvra
permits
three
categories
government
officials
perform
acting
service
vacant
pas
office
subsection
prescribes
general
rule
person
serving
pas
office
dies
resigns
otherwise
unable
perform
duties
first
assistant
office
shall
perform
office
functions
duties
temporarily
acting
capacity
next
two
paragraphs
identify
alternatives
subsection
provides
notwithstanding
paragraph
president
may
direct
person
already
serves
pas
office
perform
functions
duties
vacant
office
temporarily
acting
capacity
subsection
adds
notwithstanding
paragraph
president
may
direct
person
perform
acting
duties
person
served
senior
position
relevant
agency
least
days
period
preceding
section
also
makes
certain
individuals
ineligible
acting
service
subsection
notwithstanding
subsection
person
may
serve
acting
officer
office
section
president
nominates
vacant
pas
office
period
preceding
vacancy
individual
serve
position
first
assistant
office
served
position
less
days
subsection
creates
exception
prohibition
providing
aragraph
shall
apply
person
serving
first
assistant
position
requires
senate
advice
consent
sections
fvra
establish
time
limits
acting
service
penalties
noncompliance
cases
statute
permits
acting
service
days
beginning
date
vacancy
occurs
tolls
time
limit
nomination
pending
starts
new
clock
nomination
rejected
withdrawn
returned
upon
second
nomination
time
limit
tolls
acting
officer
serve
additional
days
second
nomination
proves
unsuccessful
fvra
ensures
compliance
providing
general
function
duty
vacant
office
performed
person
properly
serving
statute
shall
force
effect
national
labor
relations
board
nlrb
board
charged
administering
national
labor
relations
act
statute
general
counsel
must
appointed
president
advice
consent
senate
june
nlrb
general
counsel
serving
senate
confirmation
resigned
president
directed
lafe
solomon
serve
temporarily
nlrb
acting
general
counsel
citing
fvra
basis
appointment
see
memorandum
president
barack
obama
solomon
june
solomon
satisfied
requirements
acting
service
subsection
fvra
spent
previous
ten
years
senior
position
director
nlrb
office
representation
appeals
president
bigger
plans
solomon
acting
service
january
nominated
solomon
serve
nlrb
general
counsel
permanent
basis
senate
ideas
body
act
upon
nomination
congress
returned
president
legislative
session
expired
cong
rec
president
resubmitted
solomon
name
consideration
spring
may
avail
president
ultimately
withdrew
solomon
nomination
put
forward
new
candidate
senate
confirmed
october
throughout
entire
period
solomon
served
nlrb
acting
general
counsel
solomon
responsibilities
included
exercising
final
authority
issue
complaints
alleging
unfair
labor
practices
january
nlrb
regional
director
exercising
authority
solomon
behalf
issued
complaint
alleging
respondent
sw
general
company
provides
ambulance
services
improperly
failed
pay
certain
bonuses
employees
administrative
law
judge
concluded
sw
general
committed
unfair
labor
practices
nlrb
agreed
sw
general
filed
petition
review
appeals
district
columbia
circuit
argued
unfair
labor
practices
complaint
invalid
subsection
fvra
solomon
legally
perform
duties
general
counsel
nominated
fill
position
nlrb
defended
solomon
actions
contended
subsection
applies
first
assistants
automatically
assume
acting
duties
subsection
acting
officers
like
solomon
serve
appeals
granted
sw
general
petition
review
vacated
board
order
reasoned
text
subsection
squarely
supports
conclusion
provision
restriction
nominees
serving
acting
officers
applies
acting
officers
matter
whether
serve
pursuant
subsection
cadc
result
solomon
became
ineligible
serve
acting
general
counsel
president
nominated
general
counsel
granted
certiorari
affirm
ii
subsection
fvra
prevents
person
nominated
vacant
pas
office
performing
duties
office
acting
capacity
full
notwithstanding
subsection
person
may
serve
acting
officer
office
section
period
preceding
date
death
resignation
beginning
inability
serve
person
serve
position
first
assistant
office
officer
ii
served
position
first
assistant
office
officer
less
days
president
submits
nomination
person
senate
appointment
office
subsection
adds
aragraph
shall
apply
person
serving
first
assistant
position
requires
advice
consent
senate
conclude
prohibition
subsection
applies
anyone
performing
acting
service
fvra
board
contends
limited
first
assistants
performing
acting
service
subsection
text
prohibition
extends
person
serves
acting
officer
section
first
assistants
serving
subsection
phrase
otwithstanding
subsection
limit
reach
instead
clarifies
prohibition
applies
even
conflicts
default
rule
first
assistants
shall
perform
acting
duties
analysis
subsection
begins
text
subsection
applies
person
prohibits
service
acting
officer
office
section
key
words
person
section
clearly
indicate
applies
acting
officers
regardless
means
appointment
start
person
word
naturally
expansive
meaning
encompass
anyone
performs
acting
duties
fvra
see
pfizer
government
india
important
may
first
assistants
person
bunch
add
section
language
clarifies
subsection
applies
persons
serving
congress
often
drafts
statutes
hierarchical
schemes
section
subsection
paragraph
line
see
koons
buick
pontiac
gmc
nigh
filson
legislative
drafter
desk
reference
congress
used
structure
fvra
relied
make
precise
congress
wanted
refer
particular
subsection
paragraph
said
see
subsection
paragraph
congress
referred
entire
section
subsumes
ways
person
may
become
acting
officer
rest
fvra
uses
pairing
person
section
way
section
example
specifies
long
person
serving
acting
officer
described
section
may
serve
office
emphasis
added
describes
consequences
noncompliance
fvra
referring
actions
taken
person
acting
section
emphasis
added
one
disputes
provisions
apply
anyone
serving
acting
officer
fvra
first
assistants
serving
subsection
congress
intended
subsection
apply
first
assistants
acting
easily
chosen
clearer
language
replacing
person
first
assistant
done
trick
replacing
section
subsection
fact
congress
adopt
either
readily
available
apparent
alternative
strongly
supports
conclusion
subsection
applies
acting
officer
appointed
provision
within
knight
commissioner
dependent
clause
beginning
subsection
otwithstanding
subsection
confirms
prohibition
acting
service
applies
even
conflicts
default
rule
first
assistant
shall
perform
acting
duties
ordinary
meaning
notwithstanding
spite
without
prevention
obstruction
webster
third
new
international
dictionary
black
law
dictionary
ed
despite
spite
statutes
word
shows
provision
prevails
event
clash
scalia
garner
reading
law
interpretation
legal
texts
subsection
sets
rule
first
assistants
shall
perform
vacant
office
functions
duties
acting
capacity
notwithstanding
clause
subsection
means
even
first
assistant
serving
acting
officer
statutory
mandate
must
cease
service
president
nominates
fill
vacant
pas
office
subsection
also
applies
acting
officers
serving
president
behest
already
clear
broad
text
independent
clause
person
serving
section
board
takes
different
view
phrase
otwithstanding
subsection
begins
noting
uses
three
different
subsections
create
three
separate
paths
becoming
acting
official
reply
brief
prohibition
subsection
board
continues
applies
otwithstanding
one
subsections
ibid
board
view
singling
subsection
carries
negative
implication
congress
intend
subsection
override
alternative
mechanisms
acting
service
subsections
disagree
board
relies
interpretive
canon
expressio
unius
est
exclusio
alterius
one
item
associated
group
series
excludes
another
left
unmentioned
chevron
echazabal
quoting
vonn
sign
entrance
zoo
says
come
see
elephant
lion
hippo
giraffe
temporary
sign
added
saying
giraffe
sick
reasonably
assume
others
good
health
force
negative
implication
however
depends
context
marx
general
revenue
slip
expressio
unius
canon
applies
circumstances
support
sensible
inference
term
left
must
meant
excluded
echazabal
notwithstanding
clause
naturally
give
rise
inference
shows
two
provisions
prevails
event
conflict
clause
confirms
rather
constrains
breadth
singling
one
potential
conflict
might
suggest
congress
thought
conflict
particularly
difficult
resolve
quite
likely
arise
generally
imply
anything
unaddressed
conflicts
much
less
resolved
opposite
manner
suppose
radio
station
announces
play
favorite
hits
notwithstanding
fact
play
hits
play
music
british
bands
tune
expecting
hear
british
band
clash
beatles
station
announced
play
music
british
bands
notwithstanding
clause
establishes
applies
even
music
british
bands
prominently
featured
charts
one
however
think
station
singled
convey
implicitly
categorical
statement
play
music
british
bands
actually
apply
drawing
negative
inference
notwithstanding
clause
subsection
similarly
inapt
without
clause
subsection
plainly
apply
persons
serving
acting
officers
adding
notwithstanding
subsection
makes
sense
conflicts
unique
manner
former
mandatory
first
assistant
shall
perform
acting
duties
latter
contrast
speaks
may
acting
officer
vacancy
arises
president
nominates
first
assistant
fill
position
says
first
assistant
shall
perform
duties
office
acting
capacity
nomination
pending
says
may
notwithstanding
clause
clarifies
language
prevail
conflict
occurs
compare
mandatory
language
subsection
people
appointed
provisions
much
acting
officers
first
assistants
assume
role
freestanding
directive
perform
acting
duties
subsections
say
president
may
direct
natural
inference
congress
left
provisions
notwithstanding
clause
different
subsection
exempt
broad
prohibition
subsection
officers
serving
indeed
notwithstanding
used
way
parts
subsections
preceded
phrase
notwithstanding
paragraph
phrase
recognizes
subsection
unique
resolves
potential
conflict
mandatory
shall
perform
provision
permissive
may
direct
implies
nothing
potential
conflicts
may
arise
statutory
scheme
subsection
works
way
notwithstanding
clause
simply
shows
overrides
nothing
step
back
board
focus
notwithstanding
another
problem
appears
interpretation
subsection
makes
mess
subsection
specifies
shall
apply
person
person
serving
first
assistant
first
assistant
position
pas
office
senate
approved
appointment
person
office
board
interpretation
makes
first
requirement
superfluous
result
typically
try
avoid
williams
taylor
cardinal
principle
statutory
construction
must
give
effect
possible
every
clause
word
statute
internal
quotation
marks
omitted
subsection
applied
first
assistants
need
state
requirement
person
serving
first
assistant
board
proposes
congress
clarity
said
superfluous
language
board
dissent
counter
applying
prohibition
subsection
anyone
performing
acting
service
problem
also
require
applying
nullify
provision
reply
brief
dissent
deems
way
read
statute
post
agree
way
read
reading
subsection
effect
subsection
addresses
nominations
generally
prohibiting
person
nominated
fill
vacant
office
performing
office
duties
acting
capacity
subsection
speaks
specific
nomination
scenario
person
nominated
president
reappointment
additional
term
office
without
break
service
particular
situation
fvra
authorizes
nominee
continue
serve
office
commonplace
statutory
construction
specific
governs
general
radlax
gateway
hotel
llc
amalgamated
bank
general
prohibition
acting
service
nominees
yields
specific
authorization
allowing
officers
reappointment
remain
posts
applying
subsection
hardly
compels
different
result
text
subsection
clear
subject
one
narrow
exception
prohibits
anyone
nominated
fill
vacant
pas
office
performing
duties
office
acting
capacity
regardless
whether
acting
officer
appointed
subsection
limited
first
assistants
automatically
assume
acting
duties
board
contends
legislative
history
purpose
practice
uniformly
show
subsection
applies
first
assistants
text
clear
need
consider
evidence
see
state
farm
fire
casualty
ex
rel
rigsby
slip
event
board
evidence
compelling
board
argues
subsection
designed
serve
specific
purpose
preventing
president
nominee
serve
acting
officer
making
first
assistant
right
vacancy
arises
brief
petitioner
original
draft
fvra
authorized
first
assistants
pas
officers
perform
acting
service
subsection
draft
provided
first
assistant
nominated
fill
vacant
office
perform
office
duties
acting
capacity
unless
first
assistant
least
days
vacancy
several
senators
thought
fvra
restrictive
asked
add
senior
agency
officials
list
potential
acting
officers
shorten
requirement
subsection
requests
board
says
granted
final
version
fvra
included
subsection
senior
employees
shortened
requirement
days
intent
extend
prohibition
subsection
beyond
first
assistants
glitch
argument
course
text
subsection
congress
amend
statute
allow
senior
employees
become
acting
officers
subsection
substantive
change
requested
reduce
requirement
congress
done
tweaks
original
version
subsection
instead
congress
went
also
removed
language
expressly
limited
subsection
first
assistants
added
provision
subsection
makes
sense
applies
acting
officers
short
congress
took
provision
explicitly
applied
first
assistants
turned
one
applies
acting
officers
board
protests
congress
expanded
prohibition
nominees
serving
acting
officers
senators
asked
give
president
flexibility
see
brief
petitioner
certain
senators
made
specific
demands
however
mean
got
exactly
wanted
passing
law
often
requires
compromise
even
firm
public
demands
bend
competing
interests
see
ragsdale
wolverine
world
wide
congress
ultimately
agrees
text
enacts
preferences
expressed
certain
legislators
see
oncale
sundowner
offshore
services
ultimately
provisions
laws
rather
principal
concerns
legislators
compromise
precisely
happened
period
intense
negotiations
took
place
senators
demanded
changes
original
draft
fvra
final
bill
compromise
measure
rosenberg
legislation
passed
expand
pool
individuals
president
appoint
acting
officers
adding
senior
employees
subsection
also
expanded
scope
limitation
acting
service
dropping
language
making
applicable
first
assistants
board
contends
compromise
must
happened
senator
thompson
one
sponsors
fvra
said
subsection
applies
acting
officer
first
assistant
acting
officer
designated
president
pursuant
cong
rec
senator
byrd
next
speaker
offered
contradictory
account
nominee
may
serve
acting
officer
first
assistant
first
assistant
less
days
confirmed
position
good
example
floor
statements
individual
legislators
rank
among
least
illuminating
forms
legislative
history
see
milner
department
navy
us
make
use
legislative
history
believe
clear
evidence
congressional
intent
may
illuminate
ambiguous
text
take
opposite
tack
allowing
ambiguous
legislative
history
muddy
clear
statutory
finally
board
supports
interpretation
practice
notes
office
legal
counsel
government
accountability
office
issued
guidance
construing
subsection
apply
first
assistants
three
presidents
without
congressional
objection
submitted
nominations
individuals
serving
acting
officers
subsections
board
contends
historical
practice
entitled
significant
weight
fvra
concern
allocation
power
two
elected
branches
government
brief
petitioner
quoting
nlrb
noel
canning
slip
internal
quotation
marks
omitted
istorical
practice
grand
title
board
evidence
fvra
enacted
nominations
board
cites
make
less
two
percent
thousands
nominations
positions
executive
agencies
senate
considered
years
since
passage
even
guidance
documents
board
cites
paid
matter
little
attention
made
conclusory
statements
subsection
analysis
context
congress
failure
speak
fairly
imply
acquiesced
board
interpretation
see
zuber
allen
alexander
sandoval
senate
may
noticed
certain
nominees
serving
acting
officers
violation
fvra
may
chosen
reject
qualified
candidate
make
point
compliance
statute
either
least
plausible
theory
legislature
inaction
reflects
considered
acceptance
executive
practice
decision
noel
canning
chief
opinion
board
relies
sharp
contrast
case
dealt
president
constitutional
authority
recess
appointments
clause
issue
attracted
intense
attention
written
analysis
presidents
attorneys
general
senate
slip
voluminous
historical
record
dated
back
beginning
republic
included
thousands
recess
appointments
slip
chronicle
recess
appointments
clause
weighed
heavily
noel
canning
offers
support
board
iii
applying
fvra
case
straightforward
solomon
appointed
acting
general
counsel
subsection
president
submitted
nomination
fill
position
permanent
capacity
subsection
prohibited
continuing
acting
service
mean
duties
general
counsel
nlrb
needed
go
unperformed
president
appointed
another
person
serve
acting
officer
solomon
place
wide
array
individuals
choose
one
approximately
senior
nlrb
employees
hundreds
individuals
pas
positions
throughout
government
president
however
solomon
continued
service
violated
fvra
accordingly
judgment
appeals
affirmed
ordered
appendix
section
fvra
provides
officer
executive
agency
including
executive
office
president
government
accountability
office
whose
appointment
office
required
made
president
advice
consent
senate
dies
resigns
otherwise
unable
perform
functions
duties
office
first
assistant
office
officer
shall
perform
functions
duties
office
temporarily
acting
capacity
subject
time
limitations
section
notwithstanding
paragraph
president
president
may
direct
person
serves
office
appointment
required
made
president
advice
consent
senate
perform
functions
duties
vacant
office
temporarily
acting
capacity
subject
time
limitations
section
notwithstanding
paragraph
president
president
may
direct
officer
employee
executive
agency
perform
functions
duties
vacant
office
temporarily
acting
capacity
subject
time
limitations
section
period
preceding
date
death
resignation
beginning
inability
serve
applicable
officer
officer
employee
served
position
agency
less
days
rate
pay
position
described
subparagraph
equal
greater
minimum
rate
pay
payable
position
general
schedule
notwithstanding
subsection
person
may
serve
acting
officer
office
section
period
preceding
date
death
resignation
beginning
inability
serve
person
serve
position
first
assistant
office
officer
ii
served
position
first
assistant
office
officer
less
days
president
submits
nomination
person
senate
appointment
office
paragraph
shall
apply
person
person
serving
first
assistant
office
officer
described
subsection
office
first
assistant
office
appointment
required
made
president
advice
consent
senate
senate
approved
appointment
person
office
notwithstanding
subsection
president
president
may
direct
officer
nominated
president
reappointment
office
executive
department
without
break
service
continue
serve
office
subject
time
limitations
section
time
senate
acted
confirm
reject
nomination
notwithstanding
adjournment
sine
die
purposes
section
sections
expiration
term
office
inability
perform
functions
duties
office
thomas
concurring
national
labor
relations
board
petitioner
sw
general
dba
southwest
ambulance
writ
certiorari
appeals
district
columbia
circuit
march
justice
thomas
concurring
join
opinion
correctly
interprets
federal
vacancies
reform
act
fvra
et
seq
dissent
conclusion
fvra
authorized
appointment
case
however
implicates
important
constitutional
question
interpretation
whether
directing
lafe
solomon
serve
acting
general
counsel
national
labor
relations
board
nlrb
board
without
advice
consent
senate
complied
constitution
write
separately
explain
view
appointments
clause
likely
prohibited
solomon
appointment
appointments
clause
prescribes
exclusive
process
president
may
appoint
officers
germaine
accord
buckley
valeo
per
curiam
officers
appointed
accordance
clause
class
type
officer
excluded
special
functions
provides
president
shall
nominate
advice
consent
senate
shall
appoint
ambassadors
public
ministers
consuls
judges
officers
whose
appointments
herein
otherwise
provided
shall
established
law
congress
may
law
vest
appointment
inferior
officers
think
proper
president
alone
courts
law
heads
departments
art
ii
cl
purposes
appointment
clause
divides
officers
two
classes
inferior
officers
noninferior
officers
long
denominated
principal
officers
germaine
supra
principal
officers
must
appointed
president
advice
consent
senate
see
edmond
process
also
default
manner
appointment
inferior
officers
ibid
clause
provides
limited
exception
appointment
inferior
officers
congress
may
law
authorize
president
head
executive
department
law
appoint
inferior
officers
without
advice
consent
senate
ibid
fvra
governs
process
president
may
temporarily
fill
vacancy
executive
branch
office
normally
occupied
officer
relevant
case
vacancy
arises
president
may
direct
official
perform
functions
duties
office
temporarily
official
may
officer
previously
appointed
president
confirmed
senate
office
certain
employees
agency
vacancy
arose
ibid
fvra
however
require
president
seek
advice
consent
senate
directing
official
perform
functions
vacant
office
president
direct
someone
serve
officer
pursuant
fvra
appoint
ing
person
officer
within
meaning
appointments
clause
around
time
framing
verb
appoint
meant
establish
anything
decree
johnson
dictionary
english
language
def
ed
sheridan
complete
dictionary
english
language
appoint
ed
allot
assign
designate
webster
american
dictionary
english
language
def
president
direct
person
serve
acting
officer
assign
ing
designat
ing
person
serve
officer
fvra
authorizes
president
appoint
inferior
principal
officers
without
first
obtaining
advice
consent
senate
appointing
inferior
officers
manner
raises
constitutional
problems
appointments
clause
authorizes
congress
enact
law
like
fvra
vest
ing
appointment
inferior
officers
president
alone
appointing
principal
officers
fvra
however
raises
grave
constitutional
concerns
appointments
clause
forbids
president
appoint
principal
officers
without
advice
consent
senate
ii
interpret
fvra
forbid
solomon
appointment
case
need
confront
concerns
dissent
contrary
interpretation
necessarily
raises
question
whether
appointment
complied
requirements
appointments
clause
inquiry
turns
two
considerations
whether
general
counsel
nlrb
officer
within
meaning
appointments
clause
whether
principal
officer
appointed
advice
consent
view
general
counsel
plainly
officer
also
think
likely
principal
officer
initial
matter
nlrb
general
counsel
officer
whose
appointment
governed
appointments
clause
extensive
evidence
suggests
time
framing
phrase
understood
encompass
federal
officials
responsibility
ongoing
statutory
duty
mascott
officers
stan
rev
forthcoming
manuscript
online
https
last
visited
mar
see
also
officers
within
meaning
appointments
clause
op
officer
originally
understood
official
hold
position
delegated
sovereign
authority
whose
office
rather
ad
hoc
previously
held
officer
appointee
exercising
significant
authority
pursuant
laws
buckley
see
also
free
enterprise
fund
public
company
accounting
oversight
breyer
dissenting
collecting
cases
addressing
counts
officer
general
counsel
officer
probable
original
meaning
clause
precedents
charged
statute
carrying
significant
duties
exercise
general
supervision
attorneys
employed
board
officers
employees
regional
offices
final
authority
behalf
board
respect
investigation
charges
issuances
complaints
respect
prosecution
complaints
board
ibid
general
counsel
effectively
nation
prosecutor
therefore
officer
see
edmond
treating
general
counsel
department
transportation
officer
although
closer
question
general
counsel
also
likely
principal
officer
edmond
explained
officer
one
whose
work
directed
supervised
level
others
appointed
presidential
nomination
advice
consent
senate
view
consistent
original
meaning
term
practices
early
congresses
see
morrison
olson
scalia
dissenting
see
also
sheridan
supra
inferiour
johnson
supra
inferiour
def
webster
supra
inferior
contrast
principal
officer
one
superior
president
general
counsel
nlrb
appears
satisfy
definition
board
controlled
filing
complaints
prosecution
adjudication
well
nlrb
food
commercial
workers
labor
management
relations
act
ch
stat
however
effected
important
change
nlrb
structure
separat
ing
prosecuting
adjudicating
function
place
former
general
counsel
make
independent
official
appointed
president
lewis
nlrb
congress
thus
separated
nlrb
two
independent
branches
food
commercial
workers
made
general
counsel
independent
board
supervision
review
see
also
congress
decided
place
general
counsel
within
agency
make
office
independent
board
authority
moreover
general
counsel
prosecutorial
decisions
unreviewable
either
board
judiciary
nlrb
sears
roebuck
vaca
sipes
although
board
power
define
general
counsel
duties
see
general
counsel
represents
board
certain
judicial
proceedings
see
higgins
labor
czars
commissars
keeping
women
kitchen
purpose
effects
administrative
changes
made
cath
rev
statute
give
board
power
remove
otherwise
generally
control
activities
see
edmond
supra
power
remove
officers
recognized
powerful
tool
control
see
also
free
enterprise
fund
holding
executive
officials
inferior
officers
large
part
subject
superior
removal
appears
general
counsel
answers
officer
inferior
president
likely
principal
accordingly
president
likely
lawfully
appointed
solomon
serve
role
without
first
obtaining
advice
consent
senate
iii
recognize
burdens
governmental
processes
appointments
clause
imposes
may
often
seem
clumsy
inefficient
even
unworkable
ins
chadha
granting
president
unilateral
power
fill
vacancies
high
offices
might
contribute
efficient
government
appointments
clause
empty
formality
although
framers
recognized
potential
value
leaving
selection
officers
one
man
discernment
rather
fractious
multimember
body
see
federalist
cooke
also
recognized
serious
risk
abuse
corruption
posed
permitting
one
person
fill
every
office
government
see
story
commentaries
constitution
framers
lived
form
government
permitted
arbitrary
governmental
acts
go
unchecked
chadha
supra
knew
liberty
preserved
ensuring
powers
government
never
consolidated
one
body
see
federalist
thus
empowered
senate
confirm
principal
officers
view
necessity
business
appointments
considerable
salutary
restraint
upon
conduct
president
federalist
story
supra
cast
aside
separation
powers
appointments
clause
important
check
executive
power
sake
administrative
convenience
efficiency
see
bowsher
synar
senate
voluntarily
relinquished
power
fvra
make
around
appointments
clause
constitutional
clause
like
constitution
structural
provisions
designed
first
foremost
look
interests
respective
branches
protect
individual
liberty
nlrb
noel
canning
scalia
concurring
judgment
slip
internal
quotation
marks
bracket
omitted
therefore
irrelevant
branch
approves
encroachment
free
enterprise
fund
supra
internal
quotation
marks
omitted
neither
congress
executive
agree
waive
structural
provisions
constitution
agree
disregard
enumerated
right
freytag
commissioner
judicial
branch
must
vigilant
guarding
separation
political
powers
precisely
powers
collude
avoid
structural
constraints
constitution
courts
inevitably
called
upon
determine
whether
constitution
permits
appointment
principal
officers
pursuant
fvra
without
senate
confirmation
proper
interpretation
fvra
bars
appointment
sotomayor
dissenting
national
labor
relations
board
petitioner
sw
general
dba
southwest
ambulance
writ
certiorari
appeals
district
columbia
circuit
march
justice
sotomayor
justice
ginsburg
joins
dissenting
many
offices
executive
branch
may
filled
person
nominated
position
president
confirmed
senate
federal
vacancies
reform
act
fvra
cedes
senate
confirmation
authority
partially
temporary
basis
allow
executive
agencies
continue
function
one
offices
becomes
vacant
authorizes
certain
categories
officials
perform
duties
vacant
offices
acting
basis
one
provisions
pulls
back
authorization
official
nominated
fill
vacant
office
permanent
basis
scope
provision
issue
agree
provision
applies
first
assistants
vacant
office
serve
acting
officials
automatically
operation
fvra
conclusion
provision
also
applies
officials
may
serve
acting
officials
president
directs
serve
capacity
gives
provision
broader
reach
text
bear
support
history
practice
fvra
respectfully
dissent
explains
fvra
governs
vacancies
offices
held
persons
whose
appointment
office
required
made
president
advice
consent
senate
known
pas
offices
official
pas
office
dies
resigns
otherwise
unable
perform
functions
duties
office
fvra
steps
ibid
see
also
expiration
term
office
makes
official
unable
perform
functions
duties
office
section
fvra
authorizes
four
categories
officials
perform
duties
vacant
office
subsection
contains
default
rule
first
assistant
office
automatically
assumes
vacant
office
performs
functions
duties
office
temporarily
acting
capacity
subsections
authorize
president
override
default
rule
president
may
direct
person
already
confirmed
senate
pas
office
serve
acting
officer
see
president
may
direct
certain
senior
officials
agency
serve
acting
officer
see
president
may
direct
person
whose
term
office
expired
nominated
subsequent
term
office
serve
acting
officer
senate
acts
nomination
see
subsection
takes
away
authorization
specific
situation
provides
otwithstanding
subsection
first
assistant
default
rule
person
may
serve
acting
official
nominated
fill
office
person
first
assistant
office
least
days
preceding
vacancy
prohibition
subsection
apply
person
serving
first
assistant
vacant
office
see
ii
view
text
purpose
history
fvra
make
clear
prohibition
subsection
applies
first
assistant
performs
duties
vacant
office
subsection
observes
subsection
contains
potentially
broad
language
provision
specifies
person
may
serve
acting
officer
office
section
words
person
section
taken
isolation
signal
prohibition
applies
subsections
thus
covers
acting
officials
context
matters
context
cabins
words
gives
subsection
limited
reach
text
subsection
contains
clear
signal
prohibition
applies
first
assistants
automatically
assume
vacant
office
subsection
begins
clause
otwithstanding
subsection
notwithstanding
clause
identifies
potential
conflict
two
provisions
specifies
provision
prevail
familiar
expressio
unius
est
exclusio
alterius
interpretive
canon
choice
single
subsection
subsection
notwithstanding
clause
strongly
suggests
prohibition
reaches
conflicts
subsection
subsection
rest
confirms
conclusion
prohibition
subsection
establishes
may
perform
duties
vacant
office
introduces
potential
conflict
subsections
identify
four
categories
persons
may
perform
duties
vacant
office
stating
prohibition
applies
otwithstanding
subsection
subsection
expressly
prohibition
takes
precedence
default
rule
set
subsection
omission
reference
subsections
spite
parallel
potential
conflict
subsections
suggests
omission
choice
inadvertence
bruesewitz
wyeth
llc
quoting
barnhart
peabody
coal
choice
means
subsection
trumps
subsection
subsections
nothing
notwithstanding
clause
renders
impervious
established
rule
statutory
interpretation
says
rule
less
force
context
notwithstanding
clause
clause
confirms
rather
constrains
breadth
provision
attached
ante
breadth
attached
provision
precisely
question
clause
specific
reference
subsection
subsection
strongly
supports
reading
attached
prohibition
limit
subsection
see
preseault
icc
reference
notwithstanding
clause
limited
scope
attached
provision
emphasis
deleted
claims
reference
subsection
may
serve
different
purpose
view
reference
might
instead
demonstrate
congressional
concern
conflict
subsection
subsection
quite
likely
arise
particularly
difficult
resolve
ante
closer
examination
bear
hypothesis
text
refutes
theory
subsection
likely
conflict
subsection
subsections
prohibition
subsection
apply
person
served
first
assistant
vacant
office
days
year
vacancy
arose
serves
first
assistant
office
person
serving
subsection
definition
first
assistant
leg
meeting
conditions
avoiding
subsection
prohibition
altogether
serving
subsections
pas
officials
senior
agency
officials
officials
whose
terms
vacant
office
expired
prohibition
subsection
thus
likely
less
likely
conflict
subsections
true
enough
subsection
sets
automatic
rule
first
assistant
assumes
acting
status
upon
vacancy
whereas
subsections
set
conditional
rules
president
may
choose
direct
officials
assume
acting
status
distinction
makes
difference
asking
whether
conflict
subsections
harder
resolve
without
guidance
conflict
subsection
subsections
stating
may
assume
acting
status
subsection
conflicts
equally
rules
may
assume
acting
status
set
subsections
reference
subsection
subsection
notwithstanding
clause
thus
understood
means
resolve
particularly
vexing
conflict
conflict
exists
four
categories
indeed
explanations
make
notwithstanding
clause
subsection
superfluous
notwithstanding
clause
serves
confirm
breadth
subsection
singles
subsection
address
conflict
shared
equally
subsections
real
work
clause
deleted
without
changing
meaning
subsection
admits
see
ante
worse
still
broad
interpretation
subsection
renders
subsection
superfluous
subsection
president
may
designate
person
whose
term
office
expired
nominated
subsequent
term
serve
acting
official
unlikely
even
implausible
person
serves
set
term
served
first
assistant
office
year
term
expired
yet
subsection
requires
service
person
serve
acting
official
result
subsection
applies
acting
officials
prohibit
subsection
expressly
permits
acting
service
person
nominated
president
serve
consecutive
term
vacant
office
way
read
statute
problem
says
ubsection
effect
subsection
contains
specific
rule
acting
service
nominee
second
term
ordinary
principles
statutory
interpretation
controls
general
rule
governing
acting
service
nominee
subsection
ante
reasoning
point
undercuts
opening
claim
words
person
section
subsection
must
refer
anyone
performs
acting
duties
fvra
ante
underscores
otwithstanding
subsection
clause
subsection
superfluous
reading
general
authorization
acting
service
first
assistant
subsection
yield
specific
prohibition
acting
service
certain
nominees
subsection
even
without
notwithstanding
contrast
reading
subsection
apply
first
assistant
serving
acting
official
subsection
renders
provision
superfluous
reasons
subsection
reference
person
serving
first
assistant
office
superfluous
subsection
applies
first
assistants
serving
subsection
see
ante
recall
subsection
creates
exception
subsection
subsection
provides
person
serve
acting
official
nominated
person
first
assistant
vacant
office
least
days
vacancy
arose
subsection
requirements
apply
current
first
assistants
put
another
way
subsection
imposes
requirements
based
person
past
service
subsection
lifts
requirements
based
person
current
service
reference
subsection
person
serving
first
assistant
office
thus
necessary
convey
relevant
time
period
service
triggers
exception
subsection
events
leading
following
enactment
fvra
support
interpreting
subsection
apply
first
assistants
serving
subsection
first
nothing
legislative
history
fvra
indicates
subsection
enacted
broad
prohibition
acting
service
nominees
vacancies
act
fvra
predecessor
first
assistant
vacant
office
served
acting
official
unless
president
directed
another
pas
official
see
act
july
ch
stat
act
prohibit
person
first
assistant
otherwise
serving
acting
official
nominated
fill
office
structure
remained
place
century
events
prompted
fvra
enactment
confirm
line
reading
act
altered
structure
prohibit
certain
first
assistants
serving
acting
capacity
nominated
vacant
office
service
one
acting
official
bill
lann
lee
turning
point
broader
dispute
political
branches
executive
branch
compliance
vacancies
act
lee
brought
department
justice
serve
acting
assistant
attorney
general
civil
rights
division
nomination
position
failed
continued
serve
acting
capacity
renominated
position
decision
bring
lee
serve
department
justice
failed
nomination
led
strong
congressional
criticism
see
letter
fois
assistant
attorney
general
office
legislative
affairs
thurmond
pp
subsection
addresses
lee
incident
prevents
recurrence
see
explaining
earlier
version
subsection
prevent
manipulation
first
assistants
include
persons
highly
unlikely
career
officials
bars
first
assistant
serving
subsection
nominated
unless
person
first
assistant
significant
period
time
vacancy
arose
previous
days
person
first
assistant
vacant
office
contrast
indication
intent
depart
practice
vacancies
act
prohibit
acting
service
officials
nominated
vacant
office
one
identified
congressional
statements
expressing
concern
service
calling
broader
prohibition
indeed
earlier
version
subsection
unquestionably
applied
first
assistants
serving
subsection
even
though
bill
permitted
president
designate
pas
official
acting
official
instead
first
assistant
see
legislative
history
document
reason
changes
subsection
suggests
unspoken
congressional
compromise
led
expanded
subsection
ante
compromise
hypothesizes
possible
evidence
supports
absence
hint
compromise
hoped
development
debate
fvra
means
probable
second
reading
subsection
executive
branch
began
violating
fvra
almost
immediately
enactment
within
months
department
justice
office
legal
counsel
olc
advised
executive
branch
agencies
prohibition
subsection
applies
persons
serve
acting
officers
virtue
first
assistant
office
guidance
application
federal
vacancies
reform
act
op
olc
government
accountability
office
tasked
aiding
congressional
enforcement
fvra
later
reached
conclusion
see
letter
joyner
strategic
issues
thompson
chairman
senate
committee
governmental
affairs
subject
eligibility
criteria
individuals
temporarily
fill
vacant
positions
federal
vacancies
reform
act
pp
since
enactment
fvra
senate
received
nominations
persons
continued
serve
acting
capacity
nomination
satisfied
conditions
subsection
acting
service
nominee
see
app
brief
yet
legion
violations
prompted
response
evidence
suggests
senate
reacted
requiring
nominees
cease
acting
service
cf
pet
cert
citing
objections
raised
decision
failure
object
glaring
light
enforcement
mechanism
written
fvra
section
requires
executive
branch
agency
immediately
notify
comptroller
general
heads
government
accountability
office
houses
congress
vacancy
date
vacancy
occurred
name
person
serving
acting
capacity
date
service
began
name
person
nominated
senate
fill
vacancy
date
nomination
submitted
date
nomination
acted
upon
provision
leaves
doubt
congress
information
needed
object
fvra
violations
perceived
congressional
silence
face
practice
giving
subsection
narrow
reach
casts
serious
doubt
broader
interpretation
indicates
congress
like
executive
branch
interpreted
subsection
line
text
reach
first
assistants
vacant
office
serving
pursuant
subsection
fvra
prohibits
limited
set
acting
officials
confirmed
first
assistants
serve
subsection
serve
first
assistant
vacant
office
least
days
vacancy
arose
performing
duties
vacant
office
also
serving
president
nominee
fill
office
reading
provision
broadly
apply
acting
officials
disregards
full
text
fvra
finds
support
purpose
history
prefers
reading
respectfully
dissent
footnotes
senior
position
one
rate
pay
equal
greater
minimum
rate
position
general
schedule
fvra
exempts
general
counsel
national
labor
relations
board
general
rule
actions
taken
violation
fvra
void
ab
initio
appeals
assume
section
renders
actions
improperly
serving
acting
general
counsel
voidable
rejected
board
argument
voiding
solomon
actions
board
seek
certiorari
issue
consider
addition
unfair
labor
practice
complaint
case
issued
senate
returned
solomon
nomination
first
time
president
renominated
position
proceedings
board
argue
timing
made
difference
assumed
bearing
proper
application
fvra
case
proceed
assumption
footnotes
solomon
appointed
temporarily
serve
acting
general
counsel
change
analysis
think
structural
protections
appointments
clause
avoided
based
trivial
distinctions
solomon
served
three
years
office
limited
statute
term
exercised
statutory
duties
office
thus
nothing
special
temporary
solomon
appointment
eaton
morrison
used
multifactor
test
determine
whether
independent
counsel
ethics
government
act
supp
inferior
officer
although
explicitly
overrule
morrison
edmond
difficult
see
morrison
nebulous
approach
survived
opinion
edmond
edmond
also
consistent
constitution
original
meaning
therefore
guide
view
distinction
see
calabresi
lawson
unitary
executive
jurisdiction
stripping
hamdan
opinions
textualist
response
justice
scalia
colum
rev
think
general
counsel
likely
qualify
principal
officer
even
morrison
olson
see
footnotes
subsection
exception
apply
person
nominated
reappointment
additional
term
office
without
break
service
course
first
assistant
office
sw
general
offers
different
response
person
directed
perform
duties
vacant
office
subsection
serve
acting
officer
see
tr
oral
arg
also
misses
mark
like
subsections
subsection
located
titled
acting
officer
div
stat
like
subsections
addresses
may
fill
vacant
office
see
like
subsections
expressly
subjects
service
time
limits
apply
person
serving
acting
officer
described
section
moreover
relegating
officials
directed
serve
subsection
statutorily
unnamed
official
status
muddle
provisions
fvra
see
making
exclusive
means
temporarily
authorizing
acting
official
serve
pas
office
requiring
reporting
name
person
serving
acting
capacity
date
service
began
immediately
upon
designation