Professor John Plecnik’s article, “Officers Under the Appointments Clause,” was cited and quoted by the Congressional Research Service, which works exclusively for the United States Congress to provide policy and legal analysis to committees and Members of both the Senate and House.

This same article has also been cited as authority by the Supreme Court of the United States in 2018 and the United States District Court for the District of New Mexico in 2020.

A link to the report is here.