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In page National Labor Relations Board:

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In June 2010, the Supreme Court ruled in New Process Steel, L. P. v. NLRB that the two-member Board had no authority to issue decisions, invalidating all rulings made by Liebman and Schaumber.[8][full citation needed] In 2013, the question of a legitimate quorum on the NLRB surfaced again, when the United States Court of Appeals for the District of Columbia Circuit ruled that President Obama had "violated the Constitution when he bypassed the Senate to fill three board vacancies".[9]