[Jewels1091]

That was my first thought.

[aristeides]

Pickering presumably doesn't want a recess appointment, because he would have to give up his district judgeship to take it. I see no reason why Estrada couldn't be given a recess appointment.

There's plenty of precedent for recess appointments of federal judges at all levels. I am not aware of any precedent for filibustering judicial confirmations below the Supreme Court level. If it's ever happened, I'm sure it must be very rare.