I have previously blogged about the constitutional issues raised by the recess appointment of Richard Cordray as CFPB Director, both on their own, here and here, and, in connection with lawsuits that have challenged President Obama’s contemporaneous NLRB recess appointments, here, here, and here.  One of the issues flagged in those

Although there has been much discussion during the past week as to the legality of President Obama’s appointment of Richard Cordray as the first Director of the CFPB, there has been little discussion of the President’s appointment at the same time of three individuals to fill vacancies on the National Labor Relations Board (NLRB). Yet