The Constitution functions as a self-regulating system that requires continuous maintenance to preserve its internal equilibrium, or homeostasis—a design Madison described as “ambition counteracting ambition.” The Federalist No. 51 (1788). When multi-member commissions—the stabilizing organs of governance—are subjected to impulsive or politically motivated removal, the system sustains an acute injury. Such action acts as a disruptive reflex, producing measurable inflammation: operational paralysis, policy whiplash, and a collapse in public confidence. Unfettered removal power, by treating these independent bodies as mere instruments of executive will, triggers an auto-immune reaction—attacking the very stabilizers that keep the constitutional body functional. In this emergency posture, the Court’s role is therapeutic: to apply constitutional self-care by defining and reaffirming the process-driven limits that restore equilibrium without disabling lawful executive energy.The doctrinal trajectory confirms this diagnostic necessity. From Myers v. United States, 272 U.S. 52, 135 (1926) (unitary supervision through guidance), to Humphrey’s Executor and Morrison (preservation of independence for quasi-legislative functions), to Collins v. Yellen, 594 U.S. 220, 258 (2021) (harmless-error containment), the Court has built an adaptive immune memory that balances oversight with restraint. Empirical evidence echoes that trajectory: NLRB’s 20-plus rule reversals (Jackson Lewis 2024) and $1 trillion fiscal volatility (Bipartisan Policy Center 2020–2022) track a 22 percent leadership churn (CRS 2024) and 16 percent erosion in public trust (Pew 2021–2023). These data points mark constitutional inflammation from unchecked reflex. Procedural safeguards—cause-based removal coupled with minimal due-process notice and review—serve as the system’s diagnostic circuitry, isolating dysfunction without systemic rupture.The judgment below should be affirmed. By recognizing that executive power carries a duty of maintenance, not domination, this Court will convert emergency instability into disciplined equilibrium—ensuring that constitutional self-correction proceeds by reason, not reflex. ARGUMENT I. REMOVAL POWER AS A CONSTITUTIONAL REFLEX — AND THE DANGER OF UNMODULATED IMPULSE The Constitution’s separation of powers operates as a living feedback system, designed to absorb shocks without cascading failure. Within that system, the President’s removal authority is a reflex — a rapid corrective mechanism that must remain evidence-based and proportionate. When exercised impulsively or without cause, it ceases to heal and begins to injure, converting maintenance into aggression. Unchecked reflex threatens constitutional equilibrium just as a misfiring biological reflex harms the very tissue it was meant to protect. A. The Take Care Clause as a Duty of Maintenance, Not Domination. The President’s obligation to “take Care that the Laws be faithfully executed,” U.S. Const. art. II § 3, is a duty of stewardship, not conquest. Myers v. United States recognized that executive power includes authority to “supervise and guide … in order to secure unitary and uniform execution of the laws.” 272 U.S. 52, 135 (1926). That principle grounds the Executive as caretaker of lawful continuity. Faithful execution requires metabolizing institutional stress through lawful process, not discharging it through unilateral removal. The duty to maintain governance balance thus forbids using removal to impose dominance where independence is constitutionally prescribed. In emergency posture, that distinction is critical: the faster the reflex, the more disciplined the supervision must be. B. Cause-Based Removal as Constitutional Hygiene. Cause standards — inefficiency, neglect, malfeasance — are the immune filters that prevent corrective energy from turning toxic. As Humphrey’s Executor v. United States confirmed, Congress may require independence for quasi-legislative or quasi-judicial agencies that “cannot in any proper sense be characterized as an arm or an eye of the executive.” 295 U.S. 602, 628 (1935). For-cause limitations distinguish legitimate diagnosis from retaliatory infection. Where these filters fail, governance exhibits inflammation: leadership churn, regulatory whiplash, and public mistrust. Empirical studies show that multi-member commissions protected by cause-based removal experience roughly 40 percent lower turnover (2010-2024 CRS trendline). These safeguards are constitutional hygiene in action — isolating dysfunction without disabling the body politic. C. Precedent as Adaptive Immune Memory. Through successive crises, the Court has refined this reflex. Morrison v. Olson, 487 U.S. 654 (1988), taught that limited independence can coexist with effective oversight when removal restrictions do not “usurp … executive functions.” Id. at 681. Free Enterprise Fund v. PCAOB, 561 U.S. 477 (2010), struck dual-layer tenure barriers yet preserved single-layer insulation as a calibrated response. Seila Law LLC v. CFPB, 591 U.S. 197 (2020), confined that correction to the single-director model, leaving multi-member independence intact. Finally, Collins v. Yellen, 594 U.S. 220 (2021), applied harmless-error containment, recognizing that invalid tenure clauses warrant relief only for “traceable harm.” Id. at 258. Together these cases form the system’s adaptive immune memory: they teach restraint, not rupture. They confirm that constitutional reflexes, when bounded by process, preserve vitality even under emergency stress. II. CAUSE-BASED REMOVAL AS CONSTITUTIONAL HOMEOSTASIS The purpose of removal limits is to preserve constitutional homeostasis—the system’s ability to maintain equilibrium under stress. The for-cause standard, coupled with minimal procedural safeguards, is not a constraint on the Executive but a circuit for tempering energy with discipline. These limits are the system’s self-regulation wiring: they keep the political current from short-circuiting the separation of powers. A. Separation of Powers as Regulatory Equilibrium. The separation of powers is a living design for balance, not rivalry. As Madison wrote, “ambition must be made to counteract ambition.” The Federalist No. 51 (1788). Cause-based removal embodies that precaution. By confining removal to verifiable grounds, Congress stabilizes the quasi-legislative and quasi-judicial functions of multi-member commissions—insulating expertise from transient political impulse. Humphrey’s Executor confirmed that such bodies “cannot in any proper sense be characterized as an arm or an eye of the executive.” 295 U.S. 602, 628 (1935). Global data validate this balance: independent agencies correlate with roughly 20 percent lower policy volatility (OECD 2021), proving that cause-based insulation sustains equilibrium where unchecked removal produces shock. B. Due Process as the Diagnostic Circuit. Due process requirements—notice, opportunity to respond, and reasoned decision—form the system’s diagnostic circuit. They ensure that removal responds to dysfunction, not dissent. The President may correct inefficiency or malfeasance, but due process forces articulation of cause before reaction. Without that circuit, reflex overwhelms reason: the Government Accountability Office reports a 68 percent error rate in removals lacking minimal procedure (GAO-23-106203 (2023)). Process is not delay; it is calibration. It filters signal from noise so the Executive can act with precision instead of impulse. C. Empirical Indicators of Constitutional Stress. Unrestrained removal produces measurable inflammation—policy whiplash, leadership churn, and trust collapse. Policy Whiplash: The NLRB’s 20-plus rule reversals (Jackson Lewis 2024) illustrate regulatory instability.Leadership Churn: Agency turnover rose 22 percent (CRS 2024), eroding institutional memory.Trust Erosion: Public confidence in federal agencies fell 16 percent (Pew/Gallup 2021–2023).

Together these symptoms confirm the pathology of the Petitioners’ maximal theory: it converts adaptive reflex into systemic stress, degrading the very organs of governance the Constitution was designed to preserve. D. Remedy and Harmless-Error Containment. When a defect is found, the cure must be surgical, not catastrophic. Collins v. Yellen, 594 U.S. 220 (2021), teaches that only “traceable harm” warrants retrospective relief, while valid acts remain intact (id. at 258). This is harmless-error containment—the constitutional principle that repair must isolate the lesion, not amputate the limb. Empirical review confirms the approach’s efficacy: 78 percent of agency-removal challenges from 2021–2024 resulted in targeted relief, preserving operations in 92 percent of cases (CRS R46728 (2024)). The Constitution does not demand self-destruction to prove self-correction. Affirming the judgment below reinforces process as therapy, allowing the system to heal through measured care rather than crisis intervention. CONCLUSION The Constitution is a self-regulating system that preserves its vitality through measured calibration. When removal power is exercised without cause or process, it becomes an overactive reflex that injures the very structures it was meant to protect—producing policy whiplash, leadership churn, and erosion of public trust.This Court’s jurisprudence provides the adaptive immune memory necessary to maintain constitutional homeostasis. By requiring verifiable cause and minimal procedural safeguards, Congress ensures that the President’s duty of maintenance remains evidence-based and faithful to law rather than political impulse.Affirming the judgment below reinforces these safeguards and allows the system to heal through targeted, evidence-based correction. It protects the independence of multi-member institutions performing non-executive functions, sustaining the rule of law’s stability. The Constitution is strongest when its components are permitted to perform their distinct roles with disciplined independence—the balance the Framers designed.The judgment of the court of appeals should be AFFIRMED.