Two weeks after the U.S. Supreme Court held in Noel Canning that the three January 4, 2012 recess appointments to the National Labor Relations Board were invalid, the President has re-nominated one of these recess appointees to the Board. On July 10, President Obama announced his intent to nominate Sharon Block to once again be a member of the Board. Block, along with Richard Griffin and Terence Flynn, was seated on the Board while the Senate was still holding brief pro forma sessions every three days. The Court in Noel Canning determined that these sessions did not constitute a recess for appointment purposes.
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