 In "Lucia v. SEC", 585 U.S. ___ (2018), decided in June 2018, the United States Supreme Court held that 
administrative law judges are Inferior Officers within the meaning of the Appointments Clause of the United States Constitution.Another chief question is, what constitutes a "Department," when Congress seeks to place the appointment power away from the President?The phrase "Heads of Departments" has not been precisely defined by the Supreme Court.