# Trump v. Wilcox **605 U.S. ___ (2025).** The Supreme Court order of **22 May 2025** staying the reinstatement of [[NLRB]] member Gwynne Wilcox, allowing her removal to stand while litigation continued. It was an emergency-docket order rather than a merits ruling, but it did two things that mattered more than its formal posture. First, it signalled the outcome in the removal-power cases a year before [[Trump v. Slaughter]] delivered it, indicating that a majority accepted the [[Unitary Executive Theory]] claim that officers exercising executive power are removable at will notwithstanding statutory for-cause protection. Second — and this is the part with lasting structural consequence — the order gestured at an exception for the [[Federal Reserve]], describing it as a "quasi-private entity" with a "distinct historical tradition" unlike the other independent agencies. That carve-out was invented in a stay order and had no precedential foundation, but it is the doctrinal ancestor of the split outcome on **29 June 2026**, when the Court overruled [[Humphrey's Executor v. United States]] 6–3 in [[Trump v. Slaughter]] while blocking the removal of Fed governor [[Lisa Cook]] 5–4 in [[Trump v. Cook]]. The parallel case involved [[Merit Systems Protection Board]] member Cathy Harris, removed in February 2025. In December 2025 the D.C. Circuit upheld both firings. > [!note] Stub — fill out > This page was created as a stub during learning-module generation on 2026-09-05. Audit and expand when convenient: the full emergency-docket posture, Justice Kagan's dissent, the "shadow overruling" critique, and the D.C. Circuit history for both Wilcox and Harris. ## See also - [[Trump v. Slaughter]] - [[Trump v. Cook]] - [[Humphrey's Executor v. United States]] - [[Unitary Executive Theory]] - [[Merit Systems Protection Board]] - [[Central Bank Independence]]