{"id":244,"date":"2026-06-30T20:19:11","date_gmt":"2026-06-30T20:19:11","guid":{"rendered":"https:\/\/nationalconsumerreportss.com\/?p=244"},"modified":"2026-06-30T20:19:11","modified_gmt":"2026-06-30T20:19:11","slug":"slaughters-silence","status":"publish","type":"post","link":"https:\/\/nationalconsumerreportss.com\/?p=244","title":{"rendered":"Slaughter\u2019s Silence"},"content":{"rendered":"<div>\n<p>Yesterday, the Supreme Court held in  that a statutory provision limiting removal of members of the Federal Trade Commission to \u201cinefficiency, neglect of duty, or malfeasance in office\u201d violates the Constitution. In 1935, the Court upheld this statutory provision in <em>Humphrey\u2019s Executor v. United States<\/em>, establishing that Congress may limit the removal of principal officers in multimember agencies. The Supreme Court has whittled this decision away in recent years. Writing for the majority in <em>Slaughter<\/em>, Chief Justice Roberts declared, \u201cIf anything more <em>is <\/em>left of <em>Humphrey\u2019s<\/em>, we overrule it.\u201d<\/p>\n<p>Read more <a href=\"https:\/\/nationalconsumerreportss.com\/?p=242\">Rethinking Treasury\u2019s Terrorism and Financial Intelligence Office<\/a><\/p>\n<p>Overruling <em>Humphrey\u2019s Executor <\/em>was preordained. The real question was what reasoning would replace it. A  could have held that the Federal Trade Commission exercises more executive power today than it did in 1935, preserving the <em>Humphrey\u2019s Executor <\/em>exception for multimember agencies with more limited authority. A maximalist approach would embrace the most expansive form of unitary executive theory and abolish removal protections for all officers and employees within the executive branch.<\/p>\n<p>So which reasoning did the Supreme Court ultimately adopt? After reading all 191 pages in <em>Slaughter <\/em>and its sister case  (twice),I am not entirely sure.<\/p>\n<p><em>Slaughter <\/em>offers more questions than answers. At a minimum, it stands for the proposition that Congress may not limit the president\u2019s authority to remove principal officers. Given the issue presented, this should be the <em>only <\/em>holding in the case.\u00a0 Even then, the Supreme Court immediately identified a \u2014the Federal Reserve\u2014on shaky historical but strong prudential grounds. But the majority is silent on whether its decision extends to inferior officers and employees who enjoy removal protections under the Civil Service Reform Act. Moreover, <em>Slaughter <\/em>includes substantial language that can be read to expand the power to remove these actors. How one reads the majority opinion\u2014broadly or narrowly\u2014likely serves as a Rorschach test for one\u2019s overall disposition toward the administrative state and the federal workforce.<\/p>\n<p>Ultimately, <em>Slaughter<\/em>\u2019s broad language and indeterminacy provides fuel for the Trump administration to argue that the president has the constitutional prerogative to remove all inferior officers and employees\u2014regardless of whether the Supreme Court intended to protect the civil service or not. Judicial review cannot prevent the evisceration of the \u2014especially when the Supreme Court has created the system that enables such evisceration.<\/p>\n<p><strong>Who Is a \u201cSubordinate\u201d?<\/strong><\/p>\n<p>Key to interpreting <em>Slaughter<\/em> is the terminology that has governed personnel decisions for the last half century.The Supreme Court has historically placed executive-branch officials in three categories. A principal officeris someone who exercises significant authority pursuant to the laws of the United States and whose work is not directed or supervised by another officer. The Appointments Clause requires the president to appoint principal officers with the advice and consent of the Senate. An inferior officeris someone who exercises significant authority but is adequately supervised by a principal officer. Under the Appointments Clause, Congress may vest the appointment of inferior officers \u201cin the President alone, in the Courts of Law, or in the Heads of Departments.\u201d By contrast, a \u201cmere employee\u201d is an official with lesser responsibility who falls outside of the Appointments Clause. <em>Slaughter <\/em>ostensibly only involves principal officers\u2014appointees to the Federal Trade Commission.<\/p>\n<p>By default, the president has authority to remove officers and employees from their positions. The Supreme Court has recognized two notable situations where Congress may restrict the president\u2019s removal power. First, Congress may restrict the removal of inferior officers and employees. In <em>United States v. Perkins<\/em>, the Supreme Court concluded, \u201cWe have no doubt that when Congress, by law, vests the appointment of inferior officers in the heads of Departments it may limit and restrict the power of removal as it deems best for the public interest.\u201d Pursuant to this power, the Civil Service Reform Act limits the removal of most inferior officers and employees \u201conly for such cause as will promote the efficiency of the service.\u201d\u00a0<\/p>\n<p>Second, Congress may restrict the removal of principal officers who exercise \u201cquasi-judicial\u201d and \u201cquasi-legislative\u201d authority. Although \u201cquasi-judicial\u201d and \u201cquasi-legislative\u201d have a historic pedigree, the exception for these officers traces its roots at the Supreme Court to <em>Humphrey\u2019s Executor<\/em>.<\/p>\n<p>The strongest reading is that <em>Slaughter <\/em>only applies to principal officers. The Supreme Court granted certiorari on whether to overturn <em>Humphrey\u2019s Executor<\/em>, and <em>Humphrey\u2019s Executor <\/em>only concerned removal protections for principal officers in multimember agencies. Separate precedents govern Congress\u2019s authority to remove inferior officers and employees, and those precedents remain uncited by the <em>Slaughter <\/em>majority. Justice Gorsuch\u2019s concurrence supports this reading. He begins, \u201cTo fulfill his constitutional duty to ensure the laws are faithfully executed, the Court holds, the President must have the ability to remove <em>principal officers<\/em> who exercise executive power in his name\u201d (emphasis added). Justice Gorsuch also refers to the fact that the civil service laws \u201cordinarily afford rank-and-file agency employees considerable protection against removal,\u201d citing the Civil Service Reform Act. Limiting the decision to principal officers\u00a0 is the soundest reading of the Supreme Court\u2019s holding.<\/p>\n<p>Yet, Roberts\u2019s majority opinion does not provide a clean statement of its holding or any language suggesting that its reasoning does not reach inferior officers or employees. In fact, the majority opinion does not use the tripartite categorization of federal personnel to explain its logic. Roberts only uses the phrase \u201cprincipal officers\u201d a few times\u2014in quoting the Appointments Clause and Justice Story\u2014and \u201cinferior officers\u201d once in describing the Court\u2019s holding in <em>Morrison v. Olson<\/em>. Instead, he consistently refers to\u00a0 Congress\u2019s lack of authority to restrict the removal of the president\u2019s \u201csubordinates.\u201d He does quote Alexander Hamilton for the proposition that \u201c\u2018persons . . . to whose <em>immediate management<\/em> the President\u2019s powers \u2018are committed\u2019\u201d (i.e., principal officers) are subject to \u201chis superintendence\u201d (emphasis added). He also says that the Court \u201cdoes not determine the fate of officials not before us,\u201d which presumably includes inferior officers and employees. Despite this caveat, the chief justice\u2019s clearest statement swings much broader than one might anticipate from a narrow holding: \u201cSubordinates who exercise the President\u2019s power are subject to removal by him.\u201d<\/p>\n<p>The indeterminacy in Roberts\u2019s opinion leaves space for arguments that <em>Slaughter <\/em>expanded the removal power over inferior officers and employees. Textually, the phrase \u201csubordinate\u201d envisions a broader class than principal officers. If the majority only intended to limit the decision to principal officers, why evade the traditional tripartite classification? Rather than focusing on the official\u2019s category, the majority constructs a test centered on whether the \u201csubordinate\u201d exercises \u201cthe President\u2019s power\u201d (i.e., executive power). But it concludes that it \u201chas no occasion today to define the bounds of what such power entails.\u201d A principal officer who engages in enforcement, rulemaking, adjudication, legal interpretation, or litigation does so. But many employees engage in these same tasks\u2014subject to supervision by principal officers. The majority\u2019s test does not explicitly state whether supervision matters for purposes of the removal power, and the omission of supervision lends itself to a reading that the removal power extends beyond principal officers.<\/p>\n<p>The use of the word \u201csubordinates\u201d presumably derives from Chief Justice Taft\u2019s opinion in <em>Myers v. United States<\/em>. Roberts describes <em>Myers <\/em>as \u201creaffirm[ing] the President\u2019s powers to fire his subordinates at will.\u201d In <em>Myers v. United States<\/em>, the Supreme Court overturned a law requiring the president to obtain the advice and consent of the Senate prior to the removal of postmasters. The \u201csubordinate\u201d in <em>Myers <\/em>was an inferior officer. Whether the majority in <em>Slaughter <\/em>intended to import this expansive meaning of \u201csubordinate\u201d into its opinion is not clear on the face of the opinion.<\/p>\n<p><em>Myers<\/em>, however, did something that <em>Slaughter <\/em>did not: It acknowledged that Congress has the power to restrict the removal of inferior officers and employees. Citing <em>Perkins<\/em>, Taft acknowledged, \u201cCongress, in committing the appointment of such inferior officers to the heads of departments, may prescribe incidental regulations controlling and restricting the latter in the exercise of the power of removal.\u201d He also recognized that the \u201cindependent power of removal by the President alone, under present conditions, works no practical interference with the [civil service] system.\u201d Even Justice Scalia\u2014often heralded as a champion of unitary executive theory\u2014recognized that Article II \u201cdoes not require that [the president] have plenary power to remove inferior officers,\u201d because they are subordinate to principal officers.<\/p>\n<p>The omission of a similar statement is uncharacteristic of the Roberts Court, which has often mentioned that its decisions do not consider the president\u2019s authority to remove inferior officers or employees. In <em>Free Enterprise Fund v. Public Company Accounting Oversight Board<\/em>, Roberts wrote, \u201cNothing in our opinion . . . should be read to cast doubt on the use of what is colloquially known as the civil service system within independent agencies.\u201d In <em>Seila Law v. Consumer Financial Protection Bureau<\/em>, Roberts acknowledged an exception for \u201cinferior officers with limited duties and no policymaking or administrative authority.\u201d In <em>United States v. Arthrex<\/em>,Roberts remedied an Appointments Clause violation by requiring greater supervision of administrative patent judges\u2014rather than striking down their removal protections. In <em>Collins v. Yellen<\/em>, Justice Alito refused to comment on the constitutionality of the civil service. Finally, in <em>Kennedy v. Braidwood Management<\/em>, Justice Gorsuch cited the Civil Service Reform Act as an example where Congress had clearly chosen to restrict the president\u2019s removal of inferior officers and employees. <em>Slaughter <\/em>contains no such caveat, but also contains no reason to believe the Court explicitly overruled the <em>Perkins <\/em>exception.<\/p>\n<p>Roberts\u2019 majority does acknowledge several possible exceptions to the president\u2019s removal power. First, Congress may restrict removal in offices that do not \u201ccome with executive or sovereign power attached.\u201d He offers the examples of the Boy Scouts of America and Georgetown University, which are congressionally chartered entities. Second, Congress may limit the removal of governors of the Federal Reserve, because it \u201cfollows in the distinct historical tradition of the First and Second Banks of the United States.\u201d Third and finally, an open question remains for whether Congress may protect judges of \u201cnon-Article III courts, such as the Tax Court and the Court of Federal Claims,\u201d but that question was neither \u201cpresented\u201d nor \u201cbriefed.\u201d Roberts walks through these important exceptions but omits a discussion of inferior officers and employees.<\/p>\n<p>The majority knew the problem its decision created. In her dissent, Justice Sotomayor writes, \u201cToday\u2019s decision may also have major implications for inferior officers and civil-service employees, which the majority studiously ignores.\u201d The Government itself argued that its theory would extend the president\u2019s removal power to all executive-branch employees. This is not some hole discovered by a law professor sifting through a poorly reasoned decision. It has been a core issue in this case since the beginning.<\/p>\n<p>It is impossible to say for certain what Roberts intended by excluding a discussion of inferior officers and employees. One possibility is that the use of \u201csubordinate\u201d\u2014 rather than \u201cprincipal officer\u201d\u2014was necessary to secure a five-vote majority rather than a per curiam. Another possibility is that the majority believed \u201csubordinate\u201d read as sufficiently contained to \u201cprincipal officers.\u201d The final possibility is that the majority actually intends to change the test. Doing so in this fashion, however, would violate the Court\u2019s standard admonishment against \u201chiding elephants in mouseholes.\u201d<\/p>\n<p>Although the only defensible reading is that <em>Slaughter <\/em>applies to principal officers, <em>Slaughter <\/em>is a destabilizing opinion. But that destabilization may stem from its uncertainty rather than its direct effect on principal officers. Confined to principal officers, <em>Slaughter <\/em>provides the president with the opportunity to break quorums on multimember commissions and disable the functioning of the agency. Yet, many of these commissions were subject to high levels of presidential control even prior to <em>Slaughter<\/em>. Presidents often control the commission chair and that provides substantial agenda-setting authority.<\/p>\n<p>Read more <a href=\"https:\/\/nationalconsumerreportss.com\/?p=239\">Lawfare Daily: \u2018The Reverse Centaur\u2019s Guide to Life After AI\u2019\u2014A Conversation with Cory Doctorow<\/a><\/p>\n<p>The real destabilization\u2014in my mind\u2014is the Supreme Court\u2019s failure to draw a line in the sand and explicitly confine its opinion to principal officers. As written, the decision raises a number of questions about the logical extensions of its reasoning.\u00a0 Does <em>Slaughter <\/em>permit the removal of the border patrol agent who seizes drugs at the border or the Social Security clerk who denies a claim for disability benefits? Does supervision of these employees by principal officers alleviate the problem? If not, which employees exercise \u201cexecutive power\u201d and which perform non-executive functions? Those questions have significant implications for over two million federal employees and, more broadly, the ability of the executive branch to faithfully execute the law.<\/p>\n<p><strong>Judicial Review and Administrative Capacity<\/strong><\/p>\n<p>At the end of the day, <em>Slaughter <\/em>invites executive aggrandizement by encouraging presidents to pursue more aggressive cuts within the federal workforce. Indeed, Roberts\u2019s incrementalism and subtle hints of where the Court was headed led us to <em>Slaughter<\/em>. Although the Supreme Court reaffirmed <em>Humphrey\u2019s Executor <\/em>in its recent cases, its expansion of presidential power emboldened the Trump administration to defy the laws enacted by Congress by removing officials protected by the very statute <em>Humphrey\u2019s Executor <\/em>upheld.Roberts\u2019s failure to demarcate the boundaries of <em>Slaughter<\/em> invites a similar strategy\u2014regardless of whether Roberts intended that result. A Truth Social post confirmed Trump\u2019s receipt of that invitation: \u201cToday\u2019s Historic Slaughter Decision by the Supreme Court is the Greatest Increase in Presidential Power in the last 100 years. Such a Monumental Ruling at such an important time!\u201d Only time will tell precisely how the Trump administration intends to use <em>Slaughter<\/em>, but one can envision using it to justify greater cuts to the workforce.<\/p>\n<p>To whom does this expansion of presidential power pose a risk? The public. Commentators tend to frame civil-service protections in terms of \u201cfairness\u201d to federal employees. Although the civil service laws do offer protections to individuals, they exist for a greater systemic reason: To preserve administrative capacity.  describes an agency\u2019s ability to faithfully execute the laws enacted by Congress. Agencies derive this capacity, in part, from their workforces. Civil service laws promote administrative capacity by ensuring that the federal workforce does not turnover on a four-year clock.<\/p>\n<p>Proponents of unitary executive theory argue that removal protections impede faithful execution by insulating career employees from democratic direction. But much of the empirical evidence cuts the other way. plays a greater role in whether the president accomplishes his agenda. The public does not perceive presidential control as promoting accountability. Evidence already demonstrates that the Trump administration\u2019s assault on the civil service has impacted the performance of congressionally mandated activities.<\/p>\n<p>The clearest implication of <em>Slaughter<\/em>\u2014and the past year\u2019s events\u2014is that the federal courts lack ability to curb threats to administrative capacity and the president\u2019s duty to faithfully execute the law. Even if they had the will to preserve the status quo, it is unclear whether they have a way.<\/p>\n<p>A few reasons explain the skepticism toward the federal courts\u2019 ability to protect the civil service\u2014and administrative capacity\u2014in this moment. First, the Trump administration has already adopted an expansive interpretation of Article II, grasping at language in Supreme Court opinions to justify its actions. <em>Slaughter <\/em>offers more fuel with fewer guardrails than previous decisions. Cases involving the removal of immigration judges, the Senior Executive Service, and federal prosecutors; reductions in force; the implementation of Schedule Policy\/Career; and decertification of federal unions are now working their way through the federal courts. The Trump administration will likely file notices of supplemental authority in these cases, arguing that <em>Slaughter <\/em>ordains actions that would otherwise violate the civil service laws. Even before <em>Slaughter<\/em>, federal courts  about ruling on these cases because \u201cthe Supreme Court has made clear enough by way of its emergency docket that it will overrule judicially granted relief respecting hirings and firings within the executive.\u201d <em>Slaughter <\/em>itself adds to the perception among federal courts that they lack authority to enjoin actions involving federal employees\u2014even though the best reading of the decision does not extend to inferior officers or the civil service.<\/p>\n<p>Second, federal employees must exhaust their claims before the Merit Systems Protection Board (MSPB) prior to seeking review in the federal courts. Congress established the MSPB as a three-member commission to adjudicate claims arising from the Civil Service Reform Act. Even before <em>Slaughter<\/em>,the MSPB was subject to public and private pressure from the White House to erode the removal protections afforded to federal employees. The MSPB has largely kowtowed to Trump, holding that it cannot constitutionally apply the Civil Service Reform Act to certain employees. <em>Slaughter <\/em>strengthens the capture of the MSPB by calling into question whether any of its adjudicators enjoy removal protections. As the entity with the first opportunity to apply <em>Slaughter<\/em>, the MSPB is likely to use <em>Slaughter <\/em>to justify its expansion of these holdings to other categories of federal employees.<\/p>\n<p>Moreover, the federal courts cannot control the response of the federal employees and individuals who would otherwise pursue careers in the federal government. The Trump administration\u2019s personnel decisions have already shaped employee behavior, and the uncertainty wrought by <em>Slaughter <\/em>creates a broader perception that the courts will not intervene to protect them.<\/p>\n<p>Start with employees removed from their positions. <em>Slaughter <\/em>encourages the Trump administration to expand efforts to remove large swaths of the federal workforce. Even when these employees are reinstated, delays in judicial review often make a return to the federal government infeasible. Employees often seek alternative employment to pay for their homes, cars, and groceries. Meanwhile, the Trump administration\u2019s efforts to dismantle agencies move so quickly that restoring the status quo often proves impossible. In  this past year, Judge William Alsup held that the Trump administration had unlawfully fired thousands of probationary employees but refused to reinstate the employees. Alsup concluded:<\/p>\n<blockquote><p>[T]oo much water has passed under the bridge since the Supreme Court stayed this Court\u2019s preliminary injunction reinstating probationary employees. The terminated probationary employees have moved on with their lives and found new jobs. Many would no longer be willing or able to return to their posts. The agencies in question have also transformed in the intervening months by new executive priorities and sweeping reorganization. Many probationers would have no post to return to.<\/p><\/blockquote>\n<p><em>Slaughter <\/em>also increases the perception of threat among federal employees, whichmay increase voluntary turnover. Preliminary findings in ongoing research suggest that employees anticipate threats to their tenure protections and leave the federal workforce prior to the president acting on those threats. Other research has shown that perceived politicization within the workforce increases turnover intention. The Trump administration\u2019s attacks on the civil service have already sown distrust within the workforce. In a recent survey targeting all federal employees, only 10.2 percent of respondents had trust in their workplace\u2019s political leaders; 79.5 percent expressed trust in their colleagues. Only 25.2 percent reported that their agency would not tolerate \u201carbitrary action, favoritism, or political coercion against employees.\u201d By contrast, 56 percent of respondents reported that their agency would not tolerate such actions in a similar 2024 survey. Job satisfaction declined from 64 percent in 2024 to 32.7 percent in 2025. Employees are likely to perceive <em>Slaughter<\/em> as an additional threat to their positions and, therefore, some may feel pressured to leave prior to their removal.<\/p>\n<p>The same perceptions of threat may chill employees from faithfully performing their duties. All employees take an oath to uphold the Constitution and faithfully discharge their duties. At times, the faithful execution of those duties requires candid conversations with political superiors. Removal protections ensure that federal employees feel comfortable providing candid advice to superiors without a threat of retribution. Various studies demonstrate that federal employees believe it is their role to provide political appointees with candid information about how to achieve the president\u2019s agenda while leaving the ultimate policy decision to those appointees. Political appointees are likely to make worse decisions if federal employees feel they will be retaliated against for providing candid information.<\/p>\n<p>Moreover, upholding the Constitution requires federal employees to report illegal activity within the executive branch. As the government\u2019s frontline workers, federal employees are often the first to observe waste, fraud, and abuse. Removal protections provide security for whistleblowers. Today, only 22.5 percent of federal employees feel confident that they could \u201creport a suspected violation of a law, rule, or regulation without experiencing retaliation.\u201d In 2024, 72 percent of federal employees believed they could report violations of law without \u201cfear of reprisal.\u201d This fear makes it more difficult to hold the executive branch accountable by preventing the public from learning about wrongdoing.<\/p>\n<p>To be clear, <em>Slaughter <\/em>did not cause the decline in morale witnessed in recent surveys. The Trump administration\u2019s broader assault on the civil service did. But <em>Slaughter <\/em>contributes to the insecurity felt by employees by giving the Trump administration another weapon in its arsenal.<\/p>\n<p>Even if the courts manage to preserve the status quo and prevent further evisceration of administrative capacity (and I don\u2019t think they can), the erosion of the federal government\u2019s reputation as an employer will damage efforts to rebuild. The pool of individuals willing to work in the public sector is limited. For some of the professional positions that are hardest to hire,  in the federal government is about 22 percent less than in the private sector. Generally, these individuals are motivated by a  rather than money. Yet, they require assurances that they will not be removed from their positions following every election. The stability provided by civil service protections incentivizes individuals to invest time and energy into building the expertise necessary for governance. The uncertainty caused by <em>Slaughter<\/em> may chill the willingness of individuals to seek careers in government\u2014even as the Trump administration seeks to rebuild the workforce in some core agencies.<\/p>\n<p>Some will respond that the Supreme Court can always clarify its holding in a subsequent case. True. <em>Jackler v. Department of Justice<\/em>\u2014a case before the U.S. Court of Appeals for the Federal Circuit involving the removal of immigration judges\u2014would provide the Court an opportunity to decide whether the Civil Service Reform Act violates the Constitution. Even if the Court upholds Congress\u2019s authority to limit the removal of inferior officers and employees, the federal courts likely cannot prevent the damage that will be done before that hypothetical decision.<\/p>\n<p><em>Slaughter <\/em>provided the Supreme Court an opportunity to draw a line in the sand and reaffirm fundamental principles about the relationship between the president and the federal workforce. Instead, it spoke in indeterminate language that sows further doubt about the executive branch\u2019s reliability as an employer.. Its silence and opacity will cause significant confusion, instability, and the erosion of administrative capacity. One can want a smaller federal government and still want it to work. <em>Slaughter<\/em> offers neither. It does not shrink the government Congress has built\u2014that requires legislation\u2014it destabilizes the workforce that carries it out. Even readers who would happily see fewer agencies should oppose a regime that produces incompetent versions of the agencies that remain.<\/p>\n<p>The erosion of the civil service would hurt the  of the United States and the . The federal courts lack the authority, time,\u00a0 and will to preserve the status quo. Consequently, the reforms needed to preserve administrative capacity will not come from the Court but, instead, must come from Congress and\u2014most importantly\u2014the people.<\/p>\n<p>Read more <a href=\"https:\/\/nationalconsumerreportss.com\/?p=238\">Can Frontier AI Labs Lawfully Agree to Pause?<\/a><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"<p>Trump v. Slaughter\u2019s silence on the civil service raises concerns of executive aggrandizement.<\/p>\n","protected":false},"author":1,"featured_media":243,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[8],"tags":[],"class_list":["post-244","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-executive-branch"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v27.6 - https:\/\/yoast.com\/product\/yoast-seo-wordpress\/ -->\n<title>Slaughter\u2019s Silence - National Consumer Reports<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/nationalconsumerreportss.com\/?p=244\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Slaughter\u2019s Silence - National Consumer Reports\" \/>\n<meta property=\"og:description\" content=\"Trump v. 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