Independent Agency Removal Power: Humphrey's Executor Overturned with Fed Carve-Out

6-3 rulings in Slaughter and Cook overturn Humphrey's Executor, granting presidents sweeping removal power over independent agencies, but carve out a special exception for the Federal Reserve. New analysis reveals inconsistent logic. Forward-looking analysis identifies federal spending as the next separation-of-powers battleground, with 'appropriations presidentialism' emerging from fractured opinions in NIH v. APHA.