Page 858

ENDNOTES

CON! Sr OTe Os Nor

10. iA,

16. 17.

18

19

20

Ibid. 47 USC. § 154(0).

47 U.S.C. § 155(a), Ibid. Ibid. exis wou The agai

There are no ing Commissi d impose lim question is no nst removal in Communication 52 (1926) Congress could im significantly amen at that time. Consi independent coun aware of remova Chart, “FTES—His

s Act in

47 U.S.C. § 154(b)(5). httos://www.law.cornell.edu/uscode/text/47/155 (accessed January 23, 2023).

oners. Fur sonth set the h

im 996, and Con he high-profi

pose ded i derin

a n g

sels under the Independen

and protectio nd Estimated,

=

S a

powe orica

it on the Preside

imits on the President's authority to designate a different Chairperson her, though it is an open question, it is generally believed that the judiciary • power of the President to remove a Commissioner during his led because Congress did not include an express “for cause” or similar protection Communications Act i • years between the Supreme Court’s decision in Myers v. United States, 272 U.S. and Humphrey’s Executor v. United States, 295 U.S. 602 (1935), when it was no nt’s removal power. However, th

self. Scholars assume this

did not add “just cause” o temporary debates about

gress le con

ns for Fisca

Years 1986-2023,” in U.S.

t Counsel Act, one could reason presidentially appointed and Senate-confirmed officials.

47 U.S.C. § 151, https://www.law.cornell.edu/uscode/text/47/151 (accessed January 23, 2023). 47 U.S.C. § 154, httos://www.law.cornell.edu/uscode/text/47/154 (accessed January 23, 2023).

rom among the or her five-year term.

is because Congress passed the

entirely clear that • Communications Act was r other protections from removal the appointment and removal of ably assume that Congress was

Federal Communications Commission,

2023 Budget Estimates to Congress, March 2022, p. 17, https://docs.fcc.gov/public/attachments/DOC-381693A1.

pdf (accessed Jan U.S. Federal Com

Will Lapse Soon roslyniay willFor a full listing o U.S. Federal Com organization 47 U.S.C. § 230, h Thomas M. J

communica This chap ected handf every con lect a range hnson, “The

Jo

U.S. Department of Co

for Rulemaking to

ntia.gov/fcc-filing/ntia-petition

January 23, 2023).

Malwarebytes, Inc. v. Enigma Software, 592 U.S. certiorari), https://Awww.supren See 47 U.S.C. § 230; see also Ray Baum’s Act of 2018,

municati

0n/2022/04/29/spectrum-au apse-soon-if-congress-doesnt-act/?sh=4d32066908eb (accessed

al-charts

ohnson Jr., “The FCC’s Auth , 2020, https://www.fcc.gov/news-events/blog/2020/10/21/fecs-auth ions-act (accessed Jan er does not purport to set forth a comprehensive agenda for the FCC. Rather, it focuses on a may quickly rise to the attention o is chapter agrees with every policy idea inc of views and perspectives.

FCC’s Authority

ul of iss tributor to th

uary 23, 2023).

Congress Doesn't Ac

the FCC’s Bureaus an

munications Commissi

cc (accessed Jan tos://www.law.cornel

ctions-have-raised-230-billion

d Offices, along with their funct on, “Organizational Charts of th uary 23, 2023).

uary • areas tha 0 Interp

mmerce, Nationa Clarify Provision

s of Section 230 o -rulemaking-clarify-provisions-secti

necourt.gov/opinions/20pdf/19-1284_|

ority to Interpret Section 230 0

23, 2023).

uded

ret Section 230 of the Com | Telecommunications and the Commun

mun

ica

Division P. Ti

Reporting Act), in H.R. 1625, Consolidated Appropriations Act, 2018, Pu

Congress, March 23, 2018, https://www.congress.gov/

January 23, 2023).

NetChoice, L.L.C. v. Paxton, 49 F.4th 439 (5th Cir. 2022), https://fingfx.th gdpzqyobyvw/alisonn%201.pdf (accessed January 23, 2023).