No. 25-312_________________ COOK, Petitioner,v.UNITED STATES, Respondent._________________ BRIEF OF AMICUS CURIAEPRAXIS FOUNDRYIN SUPPORT OF RESPONDENT_________________ [Term], 2025_________________ [Counsel of Record Name]Counsel of Record[Law Firm or Clinic][Street Address][City, State ZIP][Phone][Email] Counsel for Amicus Curiae

TABLE OF CONTENTS INTEREST OF AMICUS CURIAE .................................................................................. 1 SUMMARY OF ARGUMENT ......................................................................................... 3 SUMMARY OF ARGUMENT — COOK v. UNITED STATES ............................................. 6 ARGUMENT .................................................................................................................. 9 I. REMOVAL POWER AS A CONSTITUTIONAL REFLEX — THE BODY TEACHING ITSELF TO HEAL .............................................................................................. 10 A. The Take Care Clause as a Duty of Maintenance, Not Domination ............ 12 B. Cause-Based Removal as Constitutional Hygiene ....................................... 14 C. Precedent as Adaptive Immune Memory .................................................... 16 D. Amici as Neural Translators ........................................................................ 18 II. CAUSE-BASED REMOVAL AS CONSTITUTIONAL HOMEOSTASIS .................... 20 A. Separation of Powers as Regulatory Equilibrium ........................................ 21 B. Due Process as the Diagnostic Circuit ......................................................... 23 C. Empirical Signals of Constitutional Stress .................................................. 25 D. Precedent as Immune Memory and Learning .............................................. 27 E. Judicial Teaching as Therapeutic Act .......................................................... 29 CONCLUSION .............................................................................................................. 31 RULE 37.6 STATEMENT ............................................................................................. 33 CERTIFICATE OF COMPLIANCE (RULE 33.1(g)) ........................................................ 34 CERTIFICATE OF SERVICE ......................................................................................... 35TABLE OF AUTHORITIES CASESCollins v. Yellen, 594 U.S. ___ (2021) (slip op.) .................................................... []Free Enterprise Fund v. Public Co. Accounting Oversight Bd., 561 U.S. 477 (2010) ... []Humphrey’s Executor v. United States, 295 U.S. 602 (1935) .................................. []Mathews v. Eldridge, 424 U.S. 319 (1976) ............................................................. []Morrison v. Olson, 487 U.S. 654 (1988) ................................................................. []Myers v. United States, 272 U.S. 52 (1926) ........................................................... []Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. ___ (2020) ....... []United States v. Virginia, 518 U.S. 515 (1996) ...................................................... [] CONSTITUTIONAL PROVISIONSU.S. Const. art. II, § 3 (Take Care Clause) ............................................................. [] STATUTES, RULES, AND OTHER AUTHORITIESSup. Ct. R. 29.3 ..................................................................................................... []Sup. Ct. R. 33.1 ..................................................................................................... []Sup. Ct. R. 37 & 37.6 ............................................................................................. [] OTHER SOURCES (CITED IN TEXT/NOTES AS CONTEXT)[Clerk Guidance on EFS & PDF security (2023–25)] ............................................... [][Empirical governance indicators referenced in “Empirical Signals”] ....................... [] RULE 37.6 STATEMENT No counsel for a party authored this brief in whole or in part, and no party or counsel for a party made a monetary contribution intended to fund the preparation or submission of this brief. No person other than amicus curiae and its counsel made such a monetary contribution. CERTIFICATE OF COMPLIANCE (RULE 33.1(g)) This brief complies with the type-volume limitation of Supreme Court Rule 33.1(g) because it contains [____] words, excluding the parts of the brief exempted by Rule 33.1(d). This brief complies with the typeface and type-style requirements of Rule 33.1(b) because it has been prepared in Century Schoolbook, 14-point type for the body and 12-point type for footnotes. Dated: October 29, 2025 /s/ [Counsel of Record Name][Counsel of Record Name]Counsel of Record for Amicus Curiae CERTIFICATE OF SERVICE I certify that on October 29, 2025, I caused this brief to be filed through the Supreme Court’s Electronic Filing System. All counsel of record who are registered EFS users will be served by the EFS. Any counsel of record not registered for the EFS will be served by [first-class mail/commercial carrier] at the addresses listed on the docket. Dated: October 29, 2025 /s/ [Counsel of Record Name][Counsel of Record Name]Counsel of Record for Amicus Curiae EFS COMPLIANCE NOTE (FOR FINAL PDF PREP — DO NOT FILE THIS PARAGRAPH) • Single consolidated PDF (≤ 20 MB), fully text-searchable, all fonts embedded; NO security restrictions.• Include document bookmarks for: TOC, TOA, INTEREST, both SUMMARIES, ARGUMENT (I–II and A–E), CONCLUSION, Rule 37.6, Certificates.• File name (public-facing): “Amicus Curiae Praxis Foundry – Cook v. United States – 2025-10-29.pdf”.• Cover color for printed booklets (if ordered later by the Clerk): dark green (Respondent support).

Respectfully submitted,Richard TaborRichard Tabor, M.A.Founder, Praxis Foundry[Address][Phone][Email]CERTIFICATE OF COMPLIANCE This brief complies with Rule 33.1(g) because it contains no more than 9,000 words, excluding the parts exempted by the Rule. It has been prepared in Century Schoolbook 14-point type for the body and 12-point type for footnotes.

INTEREST OF AMICUS CURIAE Praxis Foundry is an independent civic research and drafting initiative dedicated to strengthening human and institutional agency within constitutional governance. Its work bridges law, data, and civic design, transforming powerful emotions and public critique into defensible, measurable, and humane solutions. The Foundry operates at the intersection of scholarship and citizenship, developing legislative models, amicus briefs, and public frameworks that help government systems learn from their own errors.This is the Foundry’s first appearance before the Court. Cook v. United States is offered as a diagnostic case—one through which the Foundry introduces its method of Constitutional Physiology, a framework that treats adjudication as a process of perception, diagnosis, and repair. The Foundry appears not as a partisan or stakeholder but as a translator of feedback from the broader civic nervous system, offering the Court a structured vocabulary for restoring equilibrium where power has overreached.Viewed through the lens of physiology, the question before the Court resolves itself: power exceeded its proper bounds and became a pathogen that the law—functioning as the Republic’s immune system—has already identified and contained through the judgment affirmed below. The Foundry submits this brief to assist the Court in recognizing that the equilibrium restored here is not a political act but a constitutional reflex—evidence of a healthy system learning to heal itself. SUMMARY OF ARGUMENT The controlling question is fit. When government action grows detached from the facts it invokes, the constitutional immune system misfires. The Court’s task is not to choose a side in a policy fight, but to restore equilibrium by insisting on reasoned intent and tailoring. On the empirical record and the law, Respondents prevail because their position aligns with the system’s own repair mechanisms—procedural regularity, evidentiary grounding, and measured remedies.The Constitution is a living architecture of balance. Its nervous system is the people; its immune system is law; its mind is the network of interpreters—legislators, scholars, and amici—who translate signal into reason. When a President removes officers unilaterally and without due cause, the constitutional body experiences an autoimmune reaction: power attacking the very structures that protect it.This brief advances a theory of Constitutional Physiology (the Court’s own pattern of reflex, diagnosis, and repair). The people form its sensory field; law and procedure its immune response; the interpretive community its reflective mind; and the Court its integrating consciousness. The President’s action in this case exemplifies that reflex gone awry—an executive impulse that mistook vitality for impunity. By breaching the very limits meant to preserve institutional balance, the President triggered the autoimmune response that this Court now has the opportunity to diagnose, decide, and correct.This case is more than a dispute over removal authority; it is a diagnostic moment for the constitutional body itself. In Cook, the President’s decision to disregard statutory and structural limits functions like a physiological stress test—revealing how the system responds when one organ overexerts its energy and attacks its own immune barriers. The Court’s task, therefore, is not merely to assign fault but to assess the body’s health: whether the Constitution can restore equilibrium through reasoned intent.1. The Take Care Clause and separation-of-powers history show that the President’s duty is custodial, not predatory. Removal “for cause” preserves executive responsiveness while respecting the immune barriers of oversight and due process.2. Empirical governance data demonstrate that unchecked removal authority degrades institutional stability, generating measurable policy volatility and public-trust erosion—the systemic equivalent of inflammation.3. Constitutional precedent—from Myers to Humphrey’s Executor to Seila Law—reveals a body learning to localize power where it heals rather than harms. The Court can complete that maturation by affirming cause-based, reviewable removal as the healthy equilibrium. In doing so, the Court participates in an act of constitutional self-care: reaffirming that vitality flows not from dominance but from disciplined interdependence. SUMMARY OF ARGUMENT — COOK v. UNITED STATES The President exceeded his constitutional removal authority. Under the Court’s own physiology—reflex, diagnosis, and repair—cause-based limits function as the immune barrier that protects the Take Care Duty. Cook is the clean test case: the overreach (pathogen) is identifiable, the standard (for-cause) is objective and ex ante, and the Court has the tools to restore homeostasis. This case is diagnostic. The federal response at issue reads like an autoimmune flare in a constitutional body: an overreaction that harms what it purports to protect. Our submission does not trade rhetoric for remedy; it translates record facts and doctrine into a simple operational question: what heals the constitutional system while respecting settled limits on executive power and the Court’s own role? Cook is the first application of that method in an amicus—offered implicitly through structure and fit, not as a new rulebook.The Constitution entrusts the President with the executive power and with it the ordinary authority to supervise officers within the Executive Branch. But that authority is bounded by law. Where Congress establishes “for-cause” tenure to ensure independence in performing adjudicative or quasi-legislative duties, removal must honor the statutory standard and the basic requirements of due process. Two propositions decide this case.First, “for cause” must mean what it says. “For cause” means: (1) announced before the act, (2) tied directly to the officer’s defined duties, and (3) verified by objective facts. This is not novel. It flows from the Court’s separation-of-powers cases that both recognize presidential supervision and preserve zones of independence where Congress has validly required “good cause” (Humphrey’s Executor; Morrison v. Olson, 487 U.S. 654 (1988)) while rejecting arrangements that collapse accountability or obliterate supervision (Free Enterprise Fund v. Public Co. Accounting Oversight Bd., 561 U.S. 477, 496–97 (2010); Seila Law LLC v. Consumer Fin. Prot. Bureau, 591 U.S. ___, ___ (2020) (slip op. at 22–23). Reconciliation is straightforward: the President may not convert an officer’s lawful policy disagreement or protected adjudicatory judgment into “cause.” “Cause” is not a tantrum; it is a standard—knowable in advance and verifiable in fact.Second, removal that bypasses minimal due process is unlawful. When Congress conditions removal on cause, it necessarily imports baseline procedural safeguards so that “cause” is something other than a label. At minimum, the officer is entitled to notice of the specific grounds, a fair opportunity to respond, and a reasoned decision. This modest process tracks the Court’s functional approach to administrative and property interests (see, e.g., Mathews v. Eldridge, 424 U.S. 319, 333–35 (1976)) and the logic of cases policing unlawful removals that taint downstream actions (Free Enterprise Fund; Collins v. Yellen, 594 U.S. ___, ___ (2021) (slip op. at 27–28). Even if an officer has no lifetime property right to the job, Congress can—and here did—create a legal condition on removal. The Executive cannot nullify that condition by unilateral decree.Applied here, Respondent is correct. The President asserted “cause” without anchoring it in any pre-existing, articulated standard tied to statutory duties, dispensed with meaningful notice and hearing, and replaced legal judgment with will. That combination offends both separation of powers—by treating a statutory limit as optional—and due process—by depriving the officer of the minimal procedures that give content to “cause.”This Court does not have to weaken the unitary Executive to reject lawless removal. The path is the same one it has walked for nearly a century: preserve presidential supervision of genuinely executive functions; respect congressionally required independence for adjudicative and quasi-legislative functions; and insist that where “for-cause” protection exists, removal decisions observe an objective standard and basic process. That equilibrium keeps the system healthy: energetic execution, independent judgment where Congress has lawfully required it, and reasons—not reflex—when the two meet.This case reveals the Constitution’s own physiology at work. It is not static text but a living architecture—perceptive, corrective, and integrative. The people form its nervous system; law and procedure its immune response; the Court its consciousness. When one branch mistakes energy for exemption, that reflex turns inward and harms the very equilibrium it was meant to preserve. In restoring balance here, the Court renews the system’s capacity for reasoned care. The judgment should be affirmed. ARGUMENT Read this Summary as the Court’s diagnostic map: Section I teaches the reflex—how the Take Care structure and precedent function as the system’s immune memory; Section II teaches homeostasis—the cause-based standard that restores equilibrium through objective criteria and verifiable process. I. REMOVAL POWER AS A CONSTITUTIONAL REFLEX — THE BODY TEACHING ITSELF TO HEAL The Constitution’s design functions like a living organism: perception, response, memory, and repair. Each branch performs a vital role—executive muscle, legislative circulation, judicial perception—and together they sustain constitutional health. Removal power, properly understood, is not an impulsive twitch of authority but a reflex: a targeted response meant to preserve equilibrium. When exercised lawfully, it isolates dysfunction. When unbounded, it becomes autoimmune—power attacking the very tissues that maintain legitimacy. A. The Take Care Clause as a Duty of Maintenance, Not Domination. The President’s Article II command to “take Care that the Laws be faithfully executed,” U.S. Const. art. II, § 3, imposes a fiduciary duty of care—a term as physiological as it is legal. To take care is to tend, diagnose, decide, and repair. Faithful execution presumes continuity of lawful governance; it forbids impulsive interference with officers acting within their statutory zones of independence. “For-cause” removal converts raw power into stewardship, requiring evidence of genuine dysfunction before the scalpel is used. B. Cause-Based Removal as Constitutional Hygiene. As the immune system distinguishes pathogen from host, “for-cause” standards distinguish lawful correction from political retaliation. Congress’s authority to define “good cause” operates as an antibody, marking where oversight must be deliberate rather than reactionary. Reasons known ex ante and verifiable ex post preserve the Executive’s credibility and the system’s balance. Unchecked discretion inflames governance—policy whiplash, morale collapse, and feverish distrust. A healthy reflex requires discernment, not discharge for its own sake. C. Precedent as Adaptive Immune Memory. From Myers v. United States, 272 U.S. 52, 117–35 (1926), to Humphrey’s Executor v. United States, 295 U.S. 602, 629–32 (1935), to Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. ___ (2020), the Court’s own jurisprudence chronicles adaptation—learning when intervention heals and when it harms. Each decision represents an immune memory: a stored recognition that liberty endures not through constant assertion of dominance but through calibrated restraint. “For-cause” removal, coupled with minimal due process, is the matured reflex—energy guided by understanding. D. Amici as Neural Translators. Amici curiae occupy the constitutional “mind,” converting the system’s sensory data—public trust, institutional performance, historical experience—into reasoned signal. In submitting this brief, Praxis Foundry acts as a translator of the body’s own feedback, helping the Court perceive the pattern its precedents already trace. The act of judicial recognition becomes an act of self-knowledge: the Constitution learning how to care for itself. II. CAUSE-BASED REMOVAL AS CONSTITUTIONAL HOMEOSTASIS Energy without discipline is inflammation; discipline without energy is paralysis. The genius of the Constitution is that it preserves both movement and moderation. “For-cause” removal provisions are the circuitry through which power regulates itself—the reflex that allows executive energy to act without attacking its own legitimacy. A. Separation of Powers as Regulatory Equilibrium. The Framers did not design rival organs locked in combat but differentiated systems in mutual regulation. Each branch senses and responds to constitutional stress: Congress through legislation, the Executive through enforcement, the Judiciary through interpretation. Removal power is one such reflex—permissible when directed toward dysfunction, perilous when unleashed against lawful independence. “For-cause” tenure operates as the synapse that translates command into coordinated action rather than convulsion. B. Due Process as the Diagnostic Circuit. Process is the body’s diagnostic tool. Notice, evidence, and hearing are not bureaucratic rituals; they are the instruments by which the Republic distinguishes symptom from signal. A President who removes with cause and proof exercises judgment; one who removes by impulse mistakes pain for pathology. Minimal procedure—an articulated ground, a response opportunity, a reasoned decision—is the constitutional equivalent of testing before incision. C. Empirical Signals of Constitutional Stress. Administrative history provides the vitals. Agencies subjected to abrupt, unexplained removals exhibit measurable dysfunction: higher turnover, inconsistent enforcement, degraded morale. These are the fevers of governance. When the Executive acts through verifiable cause, the metrics stabilize—trust returns, markets cool, and legitimacy renews. The data confirm what physiology predicts: inflammation recedes when the corrective reflex is precise. D. Precedent as Immune Memory and Learning. From Humphrey’s Executor v. United States, 295 U.S. 602 (1935), to Morrison v. Olson, 487 U.S. 654, 691–93 (1988), to Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. ___ (2020), the Court’s precedents function as immune memory. Each decision stores a record of what healed and what harmed. The pattern is clear: the Constitution learns restraint through experience. Cause-based removal, bounded by process, is the evolved form of that learning—power remembering how to protect itself.
E. Judicial Teaching as Therapeutic Act. When this Court affirms that “for-cause” means fact-based and reviewable, it performs constitutional therapy. It teaches every branch that vitality depends on verifiable discipline, not arbitrary will. The judiciary becomes not an adversary but a clinician: diagnosing imbalance, prescribing boundaries, and thereby strengthening the whole. CONCLUSION The Constitution remains healthy when power is energetic and disciplined at the same time. A removal regime that demands defined, verifiable cause—and the minimal procedures that make “cause” real—keeps that balance. It allows the President to correct genuine dysfunction while preventing the autoimmune error of excising lawful independence or disagreement.This Court’s precedents already supply the immune memory for that equilibrium: supervision of executive functions, independence for adjudicative and quasi-legislative duties, and reasons—not reflex—when the two meet. Reaffirming those principles here would not weaken the Executive. It would channel its strength through diagnosis, evidence, and process—constitutional self-care rather than impulse.By holding that “for cause” means what it says—known ex ante, tied to statutory duty, proved on a reasoned record—the Court practices the very self-governance it safeguards. It teaches each branch how to heal through interpretation without harm, and it restores the public trust that follows from rule, not will.The judgment should be affirmed. Constitutional Physiology teaches that self-governance is not static; it requires continual calibration between reflex and reason. In affirming these limits, the Court practices the very equilibrium it safeguards, and, in doing so, learns to care for the Constitution as the Constitution cares for itself. I certify that on October 29, 2025, I caused this brief to be filed through the Supreme Court’s Electronic Filing System and served on all counsel of record via the EFS.