And yes, in Trump v. Slaughter, Chief Justice Roberts left room for other agency independence, but it is a dark and small room. Yes, along with Chief Justice Roberts, many modern readers assume the term is a modern legal fiction contradicting the founders’ design of the separation of powers. Chief Justice Roberts replied with a grossly misleading claim, taking a quotation out of context. Why did Chief Justice Roberts avoid any reference to the traditional tripartite categories of “principal officers,” “inferior officers,” and “employees?” How much will that change undermine the civil service, and is the civil service facing further danger?