Trump v. Slaughter · ¶203

As the years went by, Congress continued to implement forms of tenure protection. In 1791 and then 1816, it created the First and Second Banks of the United States, the former run by directors accountable only to private stockholders and the latter with only 5 (out of 25 total) removable directors. See Act of Feb. 25, 1791, 1 Stat. 192–193 (First Bank); Act of Apr. 10, 1816, 3 Stat. 269–270 (Second Bank); see Trump v. Cook, 609 U. S. 528, 536–537, 555–556 (2026) (charting development of the Banks of the United States and emphasizing the importance of their “independence”). In 1820, it passed a law making clear that a wide swath of executive officials “shall be appointed for the term of four years, but shall be removable from office at pleasure”—with the use of “but” suggesting that the 4-year fixed-term appointment otherwise would not have permitted at-will removal. Act of May 15, 1820,…

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