First, the president's removal power may be constrained by Congress if the officer in question is a member of an agency that shares similar characteristics to the Federal Trade Commission as discussed in Humphrey's Executor v. United States (1935).

Second, Congress may constrain the president's removal power over "inferior officers with limited duties and no policymaking" role as discussed in Morrison v. Olson (1988).

The Court declined to extend the exceptions to "an independent agency led by a single director and vested with significant executive power."

In 2010, it was established by the 2010 Dodd–Frank Wall Street Reform and Consumer Protection Act under President Barack Obama and the Democrat-led Congress.

In the years after it was established, Republicans gained control of the Senate, and Donald Trump became president in 2017, putting the CFPB under scrutiny.

"[6] An alert published by Holland & Knight noted that the litigation posture of Seila Law was unusual, as the CFPB declined to defend the constitutionality of its own structure before the Supreme Court.

[13] Roberts narrowly construed Humphrey's Executor[15] 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 (FTC) in 1935.

[13] In Humphrey's, the FTC was described as "exercising 'no part of the executive power'" and as "'an administrative body' that performed 'specified duties as a legislative or as a judicial aid.

[17] Roberts wrote that the CFPB structure with a single point of leadership that could only be removed for cause "ha[d] no foothold in history or tradition", and had only been used in four other instances: three modern uses for the United States Office of Special Counsel, the Social Security Administration, and the Federal Housing Finance Agency, and temporarily for one year during the American Civil War for the Office of the Comptroller of the Currency.

[21] Kagan challenged the argument presented by the majority stating that "[n]owhere does the text [of the Constitution] say anything about the president's power to remove subordinate officials at will.

"[22] Kagan also challenged Roberts' characterization of the Decision of 1789, stating that "[t]he best view is that the First Congress 'was deeply divided' on the president's removal power, and 'never squarely addressed' the central issue here.

[25] Important questions raised by commentators post-Seila include:[21] Professor Edward Cantu wrote that "[c]onsistent with how the Court has always approached separation-of-powers decisions, Seila should be viewed not as anti-pragmatic formalism but as pragmatic posturing.

[15] Thomas A. Barnico, a professor at Boston College Law School, noted that the case raised federalism issues.