However, in Seila Law LLC v. Consumer Financial Protection Bureau (2020), the Supreme Court interpreted Myers as establishing that the President generally has unencumbered removal power.

[2] Chief Justice (and former President) William Howard Taft, writing for the Court, noted that the Constitution mentions the appointment of officials but is silent on their dismissal.

In reaching its decision, the Court also expressly found the Tenure of Office Act, which had imposed a similar requirement on other Presidential appointees and was known for playing a key role in the impeachment of Andrew Johnson during the Reconstruction era, to have been invalid.

[5] In a lengthy dissent, Justice McReynolds used an equally exhaustive analysis of quotes from members of the Constitutional Convention and, writing that he found no language in the Constitution or in the notes from the Convention intended to grant the President the "illimitable power" to fire every appointed official "as caprice may suggest" in the entire government, with the exception of judges.

[7] In a separate dissent, Justice Brandeis wrote that the fundamental case deciding the power of the Supreme Court, Marbury v. Madison, "assumed, as the basis of decision, that the President, acting alone, is powerless to remove an inferior civil officer appointed for a fixed term with the consent of the Senate; and that case was long regarded as so deciding.