# Agency Head Removal Protections Crosswalk Whether the President can fire the head of a federal agency is usually discussed as one question with one answer. It is not. Every appointment statute hands its officer a different bundle, and the bundle has six slots in it: Senate confirmation, a fixed term, a qualification requirement, for-cause removal language, advance notice to Congress, and — the slot no statute contains — whether any of it has ever been made to work. This is an ASCII crosswalk of those six columns across the statutes that actually use them. The reason to draw it now is that one column was deleted. On 29 June 2026 the Supreme Court held in [[Trump v. Slaughter]] that the for-cause removal provision protecting Federal Trade Commission members is unconstitutional, and overruled [[Humphrey's Executor v. United States]]. For-cause tenure is the column that every news story, every brief and every law-review article has been about for ninety years. It is now worth nothing at an agency that exercises executive power, and the clauses themselves are still printed in the United States Code, doing nothing. What is left is the column nobody was looking at. Four statutes protect their officer not by limiting the President's grounds but by requiring him to *announce* the removal — in writing, to named recipients in Congress, sometimes on a clock. A notice requirement is not tenure and was not touched by *Slaughter*, because it never claimed the President needs a reason; only that he has to say one out loud. Part D is those four statutes, and it is also where the record is harshest: the strongest of them has never been used, and the second-strongest was broken in January 2025 by a federal court's own account, with no consequence whatsoever. Companion to [[Removal Power]], which maps the case line this page's Part B is the end of, and to [[Executive Branch Org Chart]], which maps the seats themselves. Additive to [[Federal Statistical System Tree]] and [[Federal Workforce Structure Tree]], neither of which carries the removal question at all. > [!note] How to read this chart > **★** = Senate confirmation required · **⏳** = fixed statutory term · **☐** = the statute requires advance notice of the removal to Congress · **†** = this protection was voided on 29 June 2026 · **⊘** = written in law with no remedy attached · **◎** = the hinge, the point where the protection stops deciding anything · **⚑** = a structural point worth stopping on · **◈** = this page's own arithmetic, reported by no source · **[untested]** = no removal has yet run through this clause · **[unconfirmed]** = no primary source found; not asserted. > > **No officeholder is named inside the fence.** Every row in the chart is a statute or a case, because the question here is what the law gives the seat, not who is sitting in it. The people appear in the Notes, where they are the authors or subjects of rulings rather than entries in a directory. Statutes are as in force in October 2026; the case law was read on 24 October 2026, five days after the most recent disposition on the page. ``` AGENCY HEAD REMOVAL PROTECTIONS CROSSWALK — SIX COLUMNS, AND WHICH ONE IS LEFT │ Legend: ★ Senate confirmation ⏳ fixed statutory term │ ☐ advance notice of the removal to Congress † voided 29 June 2026 │ ⊘ written in law with no remedy attached │ ◎ the hinge, where the protection stops deciding anything │ ⚑ structural point ◈ this page's own arithmetic │ [untested] no removal has yet run through this clause │ Time-slice: statutes as in force Oct 2026 · case law read 24 Oct 2026 │ No officeholder is named inside this fence. Every row is a statute or a case. │ ■ PART A — THE SIX THINGS A STATUTE CAN GIVE AN AGENCY HEAD │ Four of the six columns are about ARRIVING. One is about STAYING. One is │ about whether anything on the page has ever been made to work. │ ├─◆ 1 ... SENATE CONFIRMATION ★ │ A gate on the way in, and nothing else. Advice and consent is spent │ the day the officer is sworn. The Senate gets no role in the exit │ and has no vote to withhold once the seat is filled. │ ├─◆ 2 ... A FIXED STATUTORY TERM ⏳ │ A date, not a floor. A term says when the seat next comes open if │ nothing else happens. It does not say that nothing else may happen. │ One statute in Part E says so in terms, in the next subparagraph. │ ├─◆ 3 ... A QUALIFICATION REQUIREMENT │ "Without regard to political affiliation." "Solely on the basis of │ integrity and demonstrated ability." "Demonstrated ability to manage │ large organizations." Each of these binds the APPOINTMENT. None of │ them says one word about the removal. A qualification requirement │ is a guard against the wrong person arriving and no guard at all │ against the right person leaving. ◎ │ ├─◆ 4 ... FOR-CAUSE REMOVAL LANGUAGE † │ The only one of the six that is actually tenure: a closed list of │ grounds, and with it the implication that absent a ground the │ officer stays. This is the column that was voided. See Part B. │ ├─◆ 5 ... ADVANCE NOTICE TO CONGRESS ☐ │ Not tenure. It does not require the President to HAVE a reason, │ only to SAY one — in writing, to named recipients, sometimes by a │ deadline. Publicity, not protection. It is also, after June 2026, │ the strongest thing most of these statutes still contain. Part D. │ └─◆ 6 ... WHETHER ANY OF IT HAS BEEN TESTED The column that decides what the other five are worth, and the only one no statute contains. Supplied here from the record. ■ PART B — COLUMN 4: THE FOR-CAUSE TIER, VOIDED 29 JUNE 2026 † │ Trump v. Slaughter, No. 25-332, decided 29 June 2026, 6-3, Roberts, C.J. │ (Thomas joining except Part III-B; Gorsuch concurring; Sotomayor, Kagan │ and Jackson dissenting). Held: the for-cause removal provision protecting │ Federal Trade Commission members, 15 U.S.C. § 41, is "contrary to the │ separation of powers enshrined in the Constitution." Humphrey's Executor │ (1935) is overruled. The "quasi-legislative" and "quasi-judicial" labels │ that case ran on were "always a legal fiction," because rulemaking, │ enforcement, in-house adjudication and federal litigation are all │ executive in character. │ ├─◆ THE CLAUSE THAT WAS STRUCK, VERBATIM │ 15 U.S.C. § 41. Seven-year terms; a Commissioner may be removed by the │ President for "inefficiency, neglect of duty, or malfeasance in office." │ Those three grounds had been in the statute since 1914. │ ⚑ THE WORDS ARE STILL THERE. Nothing was repealed. The clause remains │ printed in the United States Code and no longer does anything, which │ is the condition the rest of this part describes. ⊘ │ ├─◆ THE MULTIMEMBER BODIES IN THE SAME POSITION │ │ Sixteen bodies whose members hold a fixed term under a for-cause │ │ provision, as compiled by the Congressional Research Service. Term │ │ lengths and citations are theirs. The removal WORDING of the fifteen │ │ other than the FTC was not read for this page and is not quoted. │ ├─ Chemical Safety and Hazard Invest. Board 5 yr 42 U.S.C. §7412(r)(6)(B) │ ├─ Consumer Product Safety Commission 7 yr 15 U.S.C. §2053(a) │ ├─ Federal Energy Regulatory Commission 5 yr 42 U.S.C. §7171(b)(1) │ ├─ Federal Labor Relations Authority 5 yr 5 U.S.C. §7104(b) │ ├─ Federal Maritime Commission 5 yr 46 U.S.C. §46101(b)(5) │ ├─ Federal Mine Safety and Health Rev. Comm. 6 yr 30 U.S.C. §823(b)(1) │ ├─ Federal Reserve Board of Governors 14 yr 12 U.S.C. §242 (Part C) │ ├─ Federal Trade Commission 7 yr 15 U.S.C. §41 † │ ├─ Merit Systems Protection Board 7 yr 5 U.S.C. §1202(d) † │ ├─ National Labor Relations Board 5 yr 29 U.S.C. §153(a) † │ ├─ National Mediation Board 3 yr 45 U.S.C. §154 │ ├─ National Transportation Safety Board 5 yr 49 U.S.C. §1111(c) │ ├─ Nuclear Regulatory Commission 5 yr 42 U.S.C. §5841(e) │ ├─ Occupational Safety and Health Rev. Comm. 6 yr 29 U.S.C. §661(b) │ ├─ Postal Regulatory Commission 6 yr 39 U.S.C. §502(a) │ └─ Surface Transportation Board 5 yr 49 U.S.C. §1301(b)(3) │ ├─◆ THE SINGLE-HEADED AGENCIES, WHICH LOST THE COLUMN EARLIER OR LATER │ ├─ Consumer Financial Protection Bureau ... struck in 2020, Seila Law v. │ │ CFPB. Five-year term survives; the for-cause clause did not. │ ├─ Federal Housing Finance Agency ........ struck in 2021, Collins v. │ │ Yellen, on Seila Law's reasoning. │ ├─ Office of Special Counsel ............. 5 U.S.C. § 1211(b) still reads │ │ that the Special Counsel "may be removed by the President only for │ │ inefficiency, neglect of duty, or malfeasance in office." Tested in │ │ February 2025 and ABANDONED: the officer dropped the suit in March │ │ 2025 after losing a stay, so no court ruled on the clause. ⊘ │ └─ Social Security Administration ........ 42 U.S.C. § 902(a)(3) still │ reads that the Commissioner "may be removed from office only │ pursuant to a finding by the President of neglect of duty or │ malfeasance in office." Six-year term. [untested] ⊘ │ └─◆ WHAT THE TESTS ACTUALLY PRODUCED ├─ 5 Dec 2025 — the D.C. Circuit held the for-cause protections of BOTH │ the National Labor Relations Board and the Merit Systems Protection │ Board unconstitutional, because those agencies "wield substantial │ executive power," and reversed a district court that had reinstated │ the removed members. One judge dissented. The panel did not rely on │ Slaughter, which was still pending; it relied on Seila Law and on │ Myers v. United States (1926). ├─ 19 Oct 2026 — the Supreme Court DECLINED to review the NLRB case. ⚑ │ The petition argued that the Board falls outside the removal power │ because it operates like an independent court: it decides cases by │ applying federal labour law to a record and has no investigative or │ prosecutorial powers of its own. Denying review left that argument │ unanswered by the Court, which matters because Slaughter's own │ stated limit is officers who "exercise no part of the executive │ power" — and the one petition squarely raising that limit for an │ adjudicatory board was turned away rather than decided. ◎ └─ ⚑ THE SURVIVING SHAPE OF COLUMN 4: a for-cause clause is now a sentence in the Code with no effect at any agency that exercises executive power, and the boundary of "executive power" has been drawn only by the cases the Court agreed to hear. ■ PART C — THE ONE FOR-CAUSE CLAUSE STILL STANDING │ Trump v. Cook, No. 25A312, decided the same day, 29 June 2026, 5-4 — │ Roberts, C.J., joined by Sotomayor, Kagan, Kavanaugh and Jackson, with │ Kavanaugh and Jackson also writing; Thomas, Alito (joined by Gorsuch) and │ Barrett dissenting. A different five from Part B's six. │ ├─◆ THE CLAUSE │ 12 U.S.C. § 242. Fourteen-year terms; a Governor serves the term │ "unless sooner removed for cause by the President." Cause is not │ defined anywhere in the section. │ ⚑ IT IS A WEAKER FORM OF WORDS THAN THE ONE THAT WAS STRUCK. The FTC │ clause named three grounds. This one names none. The clause that │ survived is the vaguer of the two, so the text did not decide the │ outcome — the identity of the institution did. ◎ │ ├─◆ WHAT THE COURT ADDED THAT THE STATUTE DOES NOT SAY │ A Governor is entitled to "notice and some opportunity to respond" │ before the President may remove them — a procedural floor read into a │ clause that contains no procedure. The Court rested the Board's │ position on the historical independence of central banking rather than │ on anything in § 242. │ The district judge below had read the clause as not contemplating │ "removing an individual purely for conduct that occurred before they │ began in office." The removal was blocked and the officer remains in │ the seat while the challenge proceeds. │ └─◆ WHAT THE EXCEPTION DOES NOT COVER ⚑ § 242 protects the fourteen-year SEAT. The Chairman and the two Vice Chairmen — including the Vice Chairman for Supervision, who holds the bank-regulation portfolio — are four-year DESIGNATIONS made from among the sitting Governors, and the section attaches no removal clause to any of them. The strongest tenure in the executive branch therefore protects the vote and not the gavel. ◎ ■ PART D — COLUMN 5: ADVANCE NOTICE TO CONGRESS. FOUR SHAPES, ONE REMEDY ☐ │ None of these clauses limits the President's grounds. Each requires that │ the removal be ANNOUNCED. They were not touched by June 2026, because │ they never claimed to be tenure. They are now the strongest surviving │ protection in three of the four statutes below. │ ├─◆ SHAPE 1 — SIXTY DAYS, BOTH HOUSES, IN ADVANCE ☐ │ │ Director of the Census — 13 U.S.C. § 21. │ │ ├─ ★ Senate confirmation, and appointed "without regard to political │ │ │ affiliation" │ │ ├─ ⏳ five-year term, two-term limit, one-year holdover maximum │ │ ├─ qualification requirement: a demonstrated ability to manage large │ │ │ organizations, and experience with the collection, analysis and │ │ │ use of statistical data │ │ ├─ for-cause language: NONE. The President may remove for any reason │ │ │ or for none. │ │ └─ § 21(b)(3): the President must communicate the reasons in writing │ │ to BOTH Houses "not later than 60 days before the removal." │ │ ⚑ THE LONGEST CLOCK IN THE SYSTEM, AND [untested]. No removal is │ │ recorded as having run through § 21(b)(3) since the clause was │ │ enacted in 2012. The seat has stood vacant since February 2025 │ │ after a resignation announced that January, its duties performed │ │ by a departmental official — so the strongest notice requirement │ │ in federal law protects a chair nobody currently sits in. ◎ │ ├─◆ SHAPE 2 — THIRTY DAYS, BOTH HOUSES, WITH A REASON THAT HAS TO HOLD UP ☐ │ │ Inspectors General — 5 U.S.C. § 403(b), as amended in 2022. The most │ │ demanding notice clause in federal law, and the only one that │ │ specifies CONTENT rather than merely a recipient. │ │ ├─ ★ Senate confirmation; appointed "without regard to political │ │ │ affiliation and solely on the basis of integrity and │ │ │ demonstrated ability" │ │ ├─ ⏳ fixed term: NONE │ │ ├─ written notice to both Houses and the appropriate committees "not │ │ │ later than 30 days before the removal or transfer" │ │ ├─ the notice must contain a "substantive rationale, including │ │ │ detailed and case-specific reasons" │ │ ├─ any open or completed inquiry into the Inspector General must be │ │ │ identified, and a completed one's findings included │ │ └─ non-duty status is its own 15-day written-rationale requirement │ │ and generally may not be imposed inside the 30-day window │ │ ⚑⚑ TESTED, BROKEN, AND UNREMEDIED. Seventeen Inspectors General were │ │ removed overnight on 24 January 2025 by e-mail citing "changing │ │ priorities" — no 30 days, no case-specific reasons. In Storch v. │ │ Hegseth the district court found on 24 September 2025 that the │ │ removals were UNLAWFUL and declined to reinstate anyone, on the │ │ ground that the plaintiffs had shown no irreparable harm: the │ │ President could lawfully remove them again by giving the notice. ⊘ │ │ ◎ THIS IS THE HINGE OF THE WHOLE PAGE. A notice clause's maximum │ │ value is the length of its own delay, and a court has now held │ │ that the delay is not an injury a court will restore. The most │ │ demanding notice requirement Congress has written produced a │ │ declaration that the law was broken and no change in the outcome. │ ├─◆ SHAPE 3 — REASONS TO EACH HOUSE, WITH NO CLOCK AT ALL ☐ │ │ Archivist of the United States — 44 U.S.C. § 2103(a). │ │ ├─ ★ Senate confirmation; appointed "without regard to political │ │ │ affiliations and solely on the basis of the professional │ │ │ qualifications required" │ │ ├─ ⏳ fixed term: NONE │ │ └─ "The President shall communicate the reasons for any such removal │ │ to each House of the Congress." No advance period. No deadline │ │ of any kind for the communication. │ │ ⚑ A DUTY WITH NO DUE DATE CANNOT BE LATE. The Archivist was removed │ │ in February 2025; a historians' association wrote to the White │ │ House on 10 February 2025 stating that the Administration "has not │ │ yet complied with this statute." Whether the reasons were ever │ │ communicated is [unconfirmed] here, which is itself the point: a │ │ requirement with no date attached has no moment at which a reader │ │ can say it was missed. ⊘ │ └─◆ SHAPE 4 — REASONS TO ONE CHAMBER, 1863 ☐ Comptroller of the Currency — 12 U.S.C. § 2. Five-year term, Senate confirmation, and removal by the President "upon reasons to be communicated by him to the Senate." The Senate alone; the House is not a recipient. No clock. The oldest of the four clauses by more than a century, and the narrowest. [untested in this term] ◈ THE FOUR SHAPES, SORTED BY WHAT THEY ACTUALLY COST A PRESIDENT: 60 days and two chambers · 30 days, two chambers and a defensible written case · an undated letter to two chambers · an undated letter to one. Only the first two cost any time, and only one of those has ever been put to the test — the one that failed. ◈ ■ PART E — COLUMN 2 ALONE: A FIXED TERM AND NOTHING ELSE │ These statutes give a term, a confirmation and sometimes a qualification │ requirement, and attach nothing to the exit. They are the control group, │ and they are where a fixed term can be seen doing nothing. │ ├─ Commissioner of Labor Statistics .... 29 U.S.C. § 3 │ ⏳ four years, ★ Senate-confirmed — and the term runs "unless sooner │ removed," with no grounds named and no procedure attached to the phrase. │ TESTED, 1 August 2025: removed the day a monthly jobs report was │ published, with roughly half the term unexpired, after a confirmation │ carried on 86 Senate votes. No litigation is recorded. ⚑ │ ├─ Commissioner of Internal Revenue .... 26 U.S.C. § 7803(a)(1) │ ⏳ five years, ★ Senate-confirmed, and a qualification requirement of │ "a demonstrated ability in management" — then subparagraph (D): │ the Commissioner "may be removed at the will of the President." │ ⚑⚑ THIS IS THE WHOLE OF PART A, COLUMNS 2 AND 3, WRITTEN OUT BY │ CONGRESS AND THEN ANSWERED IN THE NEXT SUBPARAGRAPH. The statute sets │ a term, sets a qualification, and says in terms that neither of them │ is a protection. Every other entry in this part means the same thing │ by saying nothing. ◎ │ └─ Director of the Federal Bureau of Investigation .. Crime Control Act of 1976, P.L. 94-503 § 203 ⏳ ten years — the longest term in the executive branch outside the Federal Reserve — ★ Senate-confirmed, no reappointment of an incumbent. The Congressional Research Service records "no statutory conditions on the President's authority to remove the Director." TESTED twice, in 1993 and in 2017, both times successfully, by Presidents of different parties. ■ PART F — OUTSIDE THE EXECUTIVE POWER ALTOGETHER │ One officer in this crosswalk has tenure that nothing in June 2026 │ touched, because the President is not on the list of people who can end │ it. │ ├─◆ Comptroller General of the United States — 31 U.S.C. § 703 │ ⏳ fifteen years, no reappointment, ★ Senate confirmation. Removable │ "at any time by (A) impeachment; or (B) joint resolution of Congress, │ after notice and an opportunity for a hearing, only for" permanent │ disability, inefficiency, neglect of duty, malfeasance, or a felony or │ conduct involving moral turpitude. The President appears nowhere in │ the removal provision. │ └─◆ WHAT THAT PROTECTION COST, AND WHY IT IS THE SAME RULE AS PART B ⚑⚑ Bowsher v. Synar, 478 U.S. 714, decided 7 July 1986, Burger, C.J. — BECAUSE Congress could remove the Comptroller General by joint resolution, he could not be given the job of executing a statute: "Congress in effect has retained control over the execution of the Act and has intruded into executive function." The budget-sequestration duties assigned to him were struck down, not his tenure. ◎ READ THE TWO HOLDINGS TOGETHER AND THEY ARE ONE RULE FROM OPPOSITE ENDS. Bowsher 1986: an officer insulated from the President may not execute the law. Slaughter 2026: an officer who executes the law may not be insulated from the President. The Comptroller General keeps the strongest removal protection in the federal government by not being an executive officer at all — which is also the only stated limit on Slaughter, officers who "exercise no part of the executive power." Forty years apart, the two opinions agree: tenure and executive power cannot sit in the same seat. ■ PART G — THE SIX COLUMNS RUN ACROSS THE FIVE TIERS │ Plus one row the statutes imply and never state: who is actually able │ to end the job. No glyphs in this grid — every cell is plain text. │ │ │ for-cause │ the Fed │ notice to │ term │ outside │ │ (voided) │ │ Congress │ only │ Article II │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Senate confirmation │ yes │ yes │ yes │ yes │ yes │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Fixed statutory term │ 3-7 yr │ 14 yr │ 0-5 yr │ 4-10 yr │ 15 yr │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Qualification req't │ varies │ none │ 3 of 4 │ 1 of 3 │ none │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ For-cause language │ VOIDED │ upheld │ none │ none │ yes │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Notice to Congress │ none │ none * │ REQUIRED │ none │ hearing ** │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Who can end the job │ President │ President │ President │ President │ Congress │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ Ever tested? │ yes │ yes │ yes │ yes │ no │ ──────────────────────┼───────────┼───────────┼───────────┼───────────┼──────────── │ What the test did │ removal │ removal │ removal │ removal │ no removal │ │ UPHELD │ BLOCKED │ held │ UPHELD, │ has ever │ │ 2025-26 │ 2026 │ UNLAWFUL │ no suit │ been │ │ │ │ and left │ filed │ attempted │ │ │ │ standing │ 2025 │ [untested] │ │ │ │ 2025 │ │ │ │ * 12 U.S.C. § 242 requires nothing of Congress. The Court read in │ "notice and some opportunity to respond" owed to the OFFICER. │ ** 31 U.S.C. § 703(e) is not notice at all: it is a joint resolution of │ Congress, after notice and a hearing, on enumerated grounds. └─◆ THE SHAPE ⚑ Read down the "Ever tested?" row and the ranking of these protections inverts. The column with ninety years of doctrine behind it was tested and lost. The column that reads strongest on paper — a closed list of grounds — turned out to be the one the Constitution would not carry. The clause that survived at the Federal Reserve is the vaguest of the lot and survived on history rather than on text. The clause that survives everywhere else, notice to Congress, survives precisely BECAUSE it concedes the President's power and asks only for a letter — and the single time a court examined one, it found the law broken and left the removal standing. That leaves one protection in this crosswalk that has never failed, and it belongs to the one officer who was told forty years ago that he may not execute the law. The price of keeping the job, in this system, is not doing the work. ``` ## Notes - **What *Slaughter* left open, and why 19 October 2026 matters.** The majority's stated limit is officers who "exercise no part of the executive power." The Court has not said where that line runs. Five days before this page was written it declined to review the removal of a National Labor Relations Board member whose petition argued precisely that an adjudicatory board sits on the far side of it — deciding cases on a record, with no investigative or prosecutorial power of its own. Denying review leaves the limit stated and unmapped, and leaves the D.C. Circuit's December 2025 reasoning ("substantial executive power") as the operative test in the circuit where most of these suits are filed. - **The struck clauses are still in the United States Code.** Nothing in *Seila Law*, *Collins v. Yellen* or *Slaughter* repealed any text. 15 U.S.C. § 41 still names three grounds; 5 U.S.C. § 1211(b) still says "only for inefficiency, neglect of duty, or malfeasance in office"; 42 U.S.C. § 902(a)(3) still requires "a finding by the President." A reader who looks up the statute will find a protection that no longer exists, which is a general hazard of reading this area from the Code alone. - **The sixteen multimember bodies are the Congressional Research Service's list, not this page's.** Position, term length and citation are reproduced from its compilation of fixed-term and for-cause provisions. The removal *wording* of the fifteen bodies other than the Federal Trade Commission was not read against the statute for this page and is deliberately not quoted. Whether each clause is identical to the FTC's three grounds is unestablished here. - **The Federal Reserve exception rests on history, not on its own words.** 12 U.S.C. § 242 says only "for cause," undefined — a weaker form of words than the clause struck down the same day. The procedural floor the Court described, "notice and some opportunity to respond," does not appear in the section; it was read into it. Secondary analysis characterises the result as a special arrangement sanctioned by the history of central banking. This page does not assert any further scope for that exception, and in particular does not assert that it extends to other financial regulators. - **What a notice requirement is for.** Three of the four statutes in Part D now carry no tenure at all, so the notice clause is the only thing in them that constrains a removal. It constrains the manner, not the decision. The Census provision is the only one that imposes a real cost — sixty days of a still-sitting director — and it has never been triggered. - **The Inspector General case is the only judicial test of a notice clause on this page.** *Storch v. Hegseth* (D.D.C.) found the January 2025 removals unlawful on 24 September 2025 and denied reinstatement for want of irreparable harm, reasoning that the President could lawfully re-effect the removals after supplying the required notice. The docket indicates the case was subsequently held pending *Slaughter* and that summary-judgment scheduling was taken up in mid-2026; no final merits judgment or appellate disposition is asserted here. - **The Archivist's reasons.** The removal occurred in February 2025. The American Historical Association's letter of 10 February 2025 states that the Administration had "not yet complied with this statute." Whether 44 U.S.C. § 2103(a)'s communication to each House was ever made is marked `[unconfirmed]`: no primary record of it was found, and because the section sets no deadline there is no date against which non-compliance could be measured. - **The Office of Special Counsel clause was tested and abandoned rather than decided.** The removed officer sued in February 2025, lost an appellate stay, and dropped the challenge in March 2025. No court ruled on 5 U.S.C. § 1211(b), so the clause's status rests on *Slaughter*'s general reasoning rather than on any holding about that statute. - **The Comptroller General's protection and *Bowsher*.** 31 U.S.C. § 703(e) is reproduced in Part F because the removal grounds matter less than who holds the power: impeachment, or a joint resolution of Congress. *Bowsher v. Synar* (1986) struck the executive duties Congress had assigned him for exactly that reason. The symmetry with *Slaughter* drawn in Part F is this page's own reading of the two holdings, offered as a reading and not as either Court's statement. - **No officeholder is named inside the chart.** Every removal on the page is identified by the statute it ran through, the date, and the court that reviewed it. This is deliberate: the seats in this crosswalk turned over hard between 2025 and 2026, and a chart built on incumbents would be a directory with a short shelf life rather than a map of what the law provides. - **What was deliberately not asserted.** No figure for the total number of officers holding any of these protections. No claim that the Federal Reserve exception reaches any other agency. No removal wording for the fifteen multimember bodies not read directly. No appellate outcome in the Inspector General litigation. No claim that the Census notice provision would or would not be complied with if used. No characterisation of the allegations underlying any individual removal. - **Questions left open.** Where the "no part of the executive power" line actually runs, and whether an adjudicatory board is on the far side of it. Whether a notice clause has any enforceable content at all after *Storch*, or whether the 60-day Census clause would fare differently because its delay is twice as long. Whether 44 U.S.C. § 2103(a)'s communication was ever made. Whether any officer has ever been removed under the Comptroller of the Currency's 1863 clause and what the Senate did with the reasons. Whether Congress can write a protection that survives *Slaughter* without also triggering *Bowsher*. - **Symbol note.** `☐` is new to this series and marks a statutory requirement that a removal be announced to Congress; it is used nine times. `†` is also new and marks a protection voided on 29 June 2026. `⊘`, `◎`, `⚑`, `◈`, `★` and `⏳` carry the meanings established in earlier maps in the series. ## See also - [[Removal Power]] · [[Trump v. Slaughter]] · [[Trump v. Cook]] · [[Trump v. Wilcox]] · [[Trump v. Boyle]] - [[Humphrey's Executor v. United States]] · [[Seila Law v. CFPB]] · [[Morrison v. Olson]] · [[Bowsher v. Synar]] · [[Storch v. Hegseth]] - [[Unitary Executive Theory]] · [[Unitary Executive Timeline]] · [[Appointments Clause]] - [[Executive Branch Org Chart]] · [[Federal Statistical System Tree]] · [[Federal Workforce Structure Tree]] · [[Inspector General Oversight Tree]] - [[How a Federal Employee Is Fired]] · [[Special Counsel Appointment and Removal Flow]] · [[Statistical Officials Crosswalk]] · [[Census Bureau Org Chart]] - [[Inspector General Act of 1978]] · [[Government Accountability Office]] · [[Federal Reserve]] · [[FTC]] · [[NLRB]] · [[Merit Systems Protection Board]] · [[Office of Special Counsel]] · [[National Archives]] · [[Bureau of Labor Statistics]] · [[IRS]] · [[FBI]] · [[SSA]] · [[CFPB]] · [[OCC]] - [[Federal Agencies Hub]] · [[Foundations Hub]]