Trump v. Slaughter · ¶115

But if Humphrey's invited very different reactions, there was perhaps one thing nearly everyone could agree on. After the Court's ruling, Congress rolled out one new “independent” agency after another. Of course, the term “independent” was always a bit of a misnomer. As we've seen, these agencies were never truly independent from politics or even the infuence of the President's appointment powers. But the leadership of these new agencies at least enjoyed protection against at-will presidential removal. And Congress turned out so many new independent agencies that a committee President Roosevelt assembled a few years later complained of the rise of a new “headless `fourth branch' of the Government, a haphazard deposit of irresponsible agencies and uncoordinated powers,” one that did “violence to the basic theory of the American Constitution.” President's Committee on Administrative…

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