After President Franklin Roosevelt took office in 1933, he became dissatisfied with Humphrey and viewed him as inadequately supportive of the New Deal.

[1] The Federal Trade Commission Act permitted the President to dismiss an FTC member only for "inefficiency, neglect of duty, or malfeasance in office."

Roosevelt's decision to dismiss Humphrey was based solely on political differences, rather than job performance or alleged acts of malfeasance.

[2] During its analysis, the Court distinguished Myers v. United States and rejected its dicta that the President has unencumbered removal powers.

[citation needed] Humphrey's was distinguished in Seila Law LLC v. Consumer Financial Protection Bureau (2020)[4] in which Chief Justice John Roberts narrowly construed Humphrey's[5] to stand for the proposition that the President's removal power may be constrained by Congress if the officer in question was a member of an agency that shared the same characteristics as the Federal Trade Commission in 1935.