interesting when you get down to Trump:
Wikipedia: Recess appointment
Presidents since George Washington have made recess appointments...
Almost every president has used recess appointments to appoint judges, over 300 such judicial recess appointments before 2000, including ten Supreme Court justices...
According to the Congressional Research Service, President Ronald Reagan made 240 recess appointments (average 30 per year) and President George H. W. Bush made 77 recess appointments (average 19 per year)...
President Bill Clinton made 139 recess appointments (average of 17 per year)…
President George W. Bush made 171 recess appointments (average of 21 per year)…
President Barack Obama made 32 recess appointments (through February 1, 2015), all to full-time positions...
***In August 2017, nine pro forma sessions were set up to block President Donald Trump from making recess appointments...
On April 15, 2020, while Congress was holding pro forma sessions due to the recess during the COVID-19 pandemic, President Trump threatened to adjourn both houses of Congress in order to make recess appointments for vacant positions such as the Federal Reserve Board of Governors and the Director of National Intelligence.[11] However, the U.S. Constitution only grants the president the authority to adjourn Congress if it is unable to agree on a date of adjournment, and both Speaker of the House Nancy Pelosi and Senate Majority Leader Mitch McConnell indicated that they would not alter the planned date of January 3, 2021...
Regardless of the Senate continuing to hold pro forma sessions, on January 4, 2012, President Obama appointed Richard Cordray and others as recess appointments...
https://en.wikipedia.org/wiki/Recess_appointment
So the rules only apply to Republican presidents, and Democrats can ignore at will.