Morrison v. Olson: Congress created the role of independent counsel in response to Watergate. The IC was appointed by an Art. III court and removable only by the Attorney General after completion of investigation or for cause. The question was whether IC was a superior or inferior officer. - Rule: If the removal restrictions impede the President's power to faithfully execute the laws, then the restrictions are unconstitutional (overrules Humphrey and to an extent Myers). - Inferior Officer Test: 1. Subordinate to a superior officer - subordinate to the AG. 2. Limited scope of duties - no policymaking discretion. 3. Limited scope of jurisdiction - only investigated executive branch officials. 4. Limited tenure - the office dissolves once the investigation is over.