In what House Speaker John Boehner called "an extraordinary and entirely unprecedented power grab by President Obama," on January 4, 2012 the President announced his intent to recess appoint Democrats Sharon Block and Richard Griffin and Republican Terence F. Flynn to the National Labor Relations Board (NLRB). These appointments will restore a quorum to the Board, which fell to two members when Member Craig Becker's recess appointment expired January 3, 2012.

President Obama nominated Ms. Block and Mr. Griffin on December 15, 2011 and nominated Mr. Flynn on January 5, 2011. Mr. Flynn is currently Chief Counsel to NLRB Board Member Brian Hayes. He previously served as Chief Counsel to former NLRB Board Member Peter Schaumber and, prior to that, was Counsel in the Labor and Employment Group of Crowell & Moring, LLP.