There's a way to have no effective recess.
The court runs from October till about the end of June so it would have to occur during that spring/summer recess but would only be good until the end of Obama's term...so nothing will be gained.
Obama got shot down by the courts on some of his appointments. He said they were in recess. The court said...like hell they were.
but the scotus will be 4 to 4 cant do anything to stop the exec order