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Chad Wolf has never been confirmed by the Senate to be DHS Sec’y. He’s been the acting sec’y longer than the Vacancies Act permits. This is one of the ways Trump destroys democratic institutions, putting people in key roles whose loyalty is to him, not the Constitution.
Acts authorized by someone in an office in violation of the Vacancies Act are void ab initio. That can be enforced by a lawsuit brought by a private party.
Posted from my iPhone/Mobile device
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