The authors thank Kirti Datla for her insightful comments on this piece.
Commentators have explored many important questions in the wake of Seila Law LLC v. Consumer Financial Protection Bureau. Do Myers v. United States and Humphrey’s Executor v. United States still stand for the proposition that Congress can impose limitations on the president’s removal authority for agency heads as long as it does not retain a role for itself?
For helpful commentary and feedback, the author thanks Hugh Brady, Dan Epstein, Matthew Reade, and The University of Chicago Law Review. The author would also like to thank Don McGahn and Annie Donaldson for their role in an incredibly formative year at the White House. This Essay reflects the author’s views only.
After former White House Counsel Donald F. McGahn refused to comply with a congressional subpoena, the U.S. House of Representatives initiated a federal lawsuit.
