John Burkoff’s Scholarship Cited in Supreme Court Opinion

Professor John Burkoff’s article, Appointment and Removal Under the Federal Constitution: The Impact of Buckley v. Valeo, 22 Wayne L.Rev. 1335, 1347, 1364 (1976), was cited approvingly this Summer by Justice Stevens in his 4-justice dissenting opinion in Free Enterprise Fund v. Public Co. Accounting Oversight Bd., 130 S.Ct. 3138 (2010). Justice Stevens cited Professor Burkoff’s research for the proposition that “[c]ourts and scholars have struggled for more than a century to define the constitutional term ‘inferior officers,’ without much success.”

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