For Appointments Clause purposes, the Supreme Court historically has refused to draw a bright line between a “principal officer” and an “inferior officer.” The vague separation between the officer ranks has caused lower courts and administrative law scholars to apply inconsistent standards in determining whether an officer is a principal or inferior. Recently, however, United States v. Arthrex adopted a bright line rule for distinguishing between officers that need to go through the formal constitutional process for appointment and officers that do not. This Essay argues that the Arthrex decision unduly burdens both the Senate and the Executive by imposing a rigid, unforgiving standard for addressing the principal-inferior officer distinction which implicitly overruled binding precedent. An examination of the Appointments Clause through a textu-alist, a purposivist, and an originalist lens suggests that the Supreme Court’s historic jurisprudence in the area adequately addresses the accountability, transparency, and authority concerns inherent in the appointments procedures. 

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