Removal of Officials
–    Typically removal at will by President
–    Congress can’t retain removal power over official with executive function (Bowsher v. Synar)
–    Statute can restrict removal if not purely executive (Humphrey’s executor)
–    but can’t restrict removal of purely executive officer (Myers – postmaster)
–    standard is whether restriction “impedes the president’s ability to perform his constitutional duty” (Morrison v. Olson)
–    Morrison (prosecutor) seems pretty executive, so unclear what is