[Engedi]

Right. Obama made a set of recess appointments although the Senate was not technically in recess in 2012. He appointed 3 national labor bureau people. In 2014 SC ruled it was illegal what he had done, though he was too late.

[Bruce Campbells Chin]

Exactly. The Supreme Court shot down the profligate use of recess appointments, which is why Obama stopped making them, and Trump hasn't made any. Pretty pathetic for a news article to not even reference that decision.