In another groundbreaking decision against the NLRB, the Fourth Circuit has followed the D.C. and Third Circuits' reasoning in Noel Canning and New Vista Nursing and Rehabilitation regarding presidential recess appointments and as a consequence, has found President Obama's January 2012 appointments invalid. In its consolidated opinion, the Court noted the following:
Three's a Crowd: Third United States Court of Appeals Decision Strikes Down President Obama's January 2012 Recess Appointments
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