Carle Hulse, Role Reversals Emerge in Dispute Over Obama’s Recess Appointments, New York Times, Jan. 10, 2014

C. Boyden Gray, the former White House counsel and ambassador, is among the conservative lawyers urging the Supreme Court to severely constrain the Obama administration’s ability to fill executive branch vacancies during a Senate recess. Mr. Gray is exceptionally well versed in the subject, having received his own recess appointment in 2006.