STEVEN CALABRESI: Justice Barrett, Trump v. Slaughter, and Presidential Removal Power from 1881 to 1901. “During the oral argument in Trump v. Slaughter, Justice Amy Coney Barrett asked counsel for respondent Slaughter how long independent agencies had existed for and counsel suggested to her, incorrectly, that they dated back to the last twenty years of the 19th Century. In fact, as I will show in a series of posts on this blog, no truly independent agency ever existed prior to the decision in Humphrey’s Executor v. United States in 1935.”