[Phantom Lord]

The ONLY way Billy Jeff could POSSIBLY become President again would be to be appointed VP, then succeed to the highest office via death or removal from office.

And that wouldn't work because his nomination to be VP would be unconstitutional and would be prevented. The Senate would never get a chance to vote on the nomination.

[SoCal Pubbie]

I would think you’re right, however, the wording of the 22 Amendment states only that “No person shall be elected to the office of the President more than twice”. I have heard it stated that this would not cover someone who rose say from the Senate to VP to President, as Ford did.