Noting that the Framers “provided for Congress to convene every year” in contextual analysis of meaning of “recess” (that is, the intersession recess) in the Recess Appointments Clause.
Frank B. Cross, Executive Orders 12,291 and 12,498: A Test Case in Presidential Control of Executive Agencies, 4 J.L. & Pol. 483 (1988).
Arguing that providing that “Congress need not be convened until December of each year . . . plainly evinces an intent to have the executive assume a substantial role in the operation of the federal government.”
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