Abstract
governors who supported the suit,4 but the U.S. District Court for the District of Columbia granted an injunction preventing Bush from removing any of the governors.5 The President nonetheless continued to pursue his goal. He waited until a recess of the Senate6 to replace one of the governors who supported the suit, Crocker Nevin, with Thomas Ludlow Ashley,7 a longtime friend who Bush believed would oppose the suit.8 Bush thus skirted the usual procedure for presidential appointments, in which the Senate must confirm the President's nomi-
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