In Seila Law LLC v. Consumer Financial Protection Bureau (2020), the Supreme Court distinguished Morrison as a narrow exception applying only to inferior officers.

The Chairman of the Judiciary Committee forwarded a copy of the report to the Attorney General with a request that he seek the appointment of an independent counsel to investigate the allegations against Olson and two others.

[9] In his opinion, Scalia predicted how the law might be abused in practice, writing, "I fear the Court has permanently encumbered the Republic with an institution that will do it great harm.

[1][2][3][4][5][6][7][8] Conservatives like Senator Bob Dole shared similar concerns when Lawrence Walsh announced the re-indictment of former defense secretary Caspar Weinberger on charges related to the Iran–Contra affair four days before the 1992 U.S. presidential election.

Concerns were also raised, in line with Scalia's dissent, when independent counsel Kenneth Starr spent $40 million and more than four years investigating President Clinton's land deals and extramarital affairs.

"[15]In April 2006, a court citing Morrison rejected I. Lewis "Scooter" Libby's argument that Special Counsel Patrick J. Fitzgerald lacked the legal authority to bring charges against him.

[16] Morrison was distinguished in Seila Law LLC v. Consumer Financial Protection Bureau (2020) as being an exception to the President's generally unencumbered authority to remove officers of the United States at will.