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Theunitary executive theoryis a controversial legal theory inUnited States constitutional lawwhich holds that thepresident of the United Statespossesses thepowerto control the entirefederal executive branch.

The doctrine interprets a part ofArticle Two of the United States Constitution,which vests "the executive Power" of the United States in the president, to make the case for expanded power, though other clauses within the Constitution such as theOpinions Clauseand theNecessary and Proper Clausehave been cited to contradict the unitary executive theory.[1][2]ThePresident of the United Stateshas exercised significant authority over the executive branch, with some exceptions, including independent agencies such as theFederal Reserve,and independent personnel such asspecial counsels.[1][2]These limits on unitary executive power have been created byCongressor bySupreme Courtdecisions. Since the founding of the country, positions independent of the executive have includedComptroller,Postmaster Generaland theSinking Fund Commission.[2][1]More recent Republican presidential administrations have been the most aggressive to expand presidential powers, most notably theReagan administration,the post 9/11George W. Bush administration,and theTrump administration.

Examples of similar theories in practice can be seen inbacksliding democracieswhere they are often described as a form ofexecutive aggrandizement.The experience of similar reforms in former democracies strongly suggests that creating a unitary executive paves the way forautocracy.[3]In the United States, no state governments have implemented such a theory.

The theory has received substantial criticism, including as a "quasi legal doctrine",[4]"laughable",[5]and "a defining characteristic of autocracy."[6]

Theory[edit]

TheVesting ClauseofArticle IIprovides, "The executive Power [of the United States] shall be vested in a President of the United States of America." Proponents of the unitary executive theory argue that this language, along with theTake Care Clause( "The President shall take care that the laws be faithfully executed..." ), creates a "hierarchical, unified executive department under the direct control of the President."[7]Critics point out that the clause does not specify that the President should be the one to execute the laws, but to make sure that others are faithfully executing their responsibilities. Opponents also point to theOpinion clause,which states only that a President may ask for the opinion in writing of what a Department officer thinks about any subject related to their department.[8]

More extreme forms of the theory have developed in which the president’s wishes exceed the law. FormerWhite House CounselJohn Deanexplains: "In its most extreme form, unitary executive theory can mean that neither Congress nor the federal courts can tell the President what to do or how to do it, particularly regarding national security matters."[9]Law ProfessorIlya Sominargued in 2019 that no serious advocate of the theory claims that anything the president does is legal - just within the powers vested in the executive branch.[10]

According to law professorsLawrence LessigandCass Sunstein,"No one denies that in some sense the framers created a unitary executive; the question is in what sense. Let us distinguish between a strong and a weak version."[2]In either its strong or weak form, the theory would limit the power of Congress to divest the president of control of the executive branch. The "strongly unitary" theory posits stricter limits on Congress than the "weakly unitary" theory.[2]Parts of the Constitution, however, grant extensive powers to Congress. Article I of the Constitution gives Congress the exclusive power to make laws, which the president then must execute, provided that those laws are constitutional. Article I, Section 8, clause 18 of the Constitution known as theNecessary and Proper Clausegrants Congress the power to "make all Laws which shall be necessary and proper for carrying into Execution all Powers vested by this Constitution in the Government of the United States, or in any Department or Officer thereof". The Constitution alsogrants Congress power"To make Rules for the Government and Regulation of the land and naval Forces." Any legitimate theory of the unitary executive must allow Congress to wield its constitutional powers while ensuring that the president can do the same.[citation needed]

Proponents of a strongly unitary theory argue that the president possessesallof the executive power and can therefore control subordinate officers and agencies of the executive branch. This implies that the power of Congress to remove executive agencies or officers from presidential control is limited. Thus, under the strongly unitary executive theory, independent agencies and counsels are unconstitutional to the extent that they exercise discretionary executive power not controlled by the president.[7]However, such agencies do exist and have for at least a century. The existence of such agencies has been upheld by the courts (see Humphries Executor for an example).[needs copy edit][original research?]Some interpret the Unitary Executive Theory to mean thatfederal courtscannot adjudicate disputes betweenagencies,arguing it would violate the doctrine ofseparation of powers.[11]

Proponents draw on claims about the powers they argue were wielded by theKing of Englandat the time of the founding to justify the theory, though the actual powers held by the Crown are disputed as 'conventional wisdoms' by legal historians who counter that parliament held significant power over appointments and dismissals of some executive personnel.[12]Daniel Birk argues there was no evidence of the King having such powers outside of specific areas like foreign policy and the military, noting the King could not direct most law enforcement, regulatory or administrative officials.[12]Birk criticizes some proponents of the strong unitary executive theory as being inconsistent over the originalism used to justify the theory.[12]Invoking the King as an argument for expanded executive power was first made by then-Chief JusticeWilliam Howard Taftin 1926.[12]Others have argued that the founding was an explicit rejection of monarchy and find the premise of looking at the powers held by a King objectionable.[13]Eric Nelson argued that some Founders wanted more checks on a president because unlike a hereditary monarch, their wellbeing was not as intrinsically tied to the nation.[14]

Criticism of the strong version of the theory[edit]

See also:Democratic backsliding in the United StatesandExecutive aggrandizement

TheBBCdescribed the theory as "controversial,"[15]whileThe Guardiandescribed it as "contested"[16]and a "quasi legal doctrine."[4]Norman Ornsteinsaid an overwhelming majority of constitutional scholars and historians find the theory to be "laughable."[17]

David Driesen argued that unitary control over the executive as a defining characteristic of autocracy.[6]Steven Greenhut argues the theory is a prescription for abuse and authoritarianism.[18]Brynn Tannehill writing inThe New Republiccites those who study how democracies die as arguing that the theory is "a big, flashing neon light that democracy is either dead or dying."[19]

Some scholars oppose even the "weakly unitary" theory. Some favor a plural executive, such as in the many state governments that separately elect an attorney general.[20]Others favor a view in which Congress and the president share control over the bureaucracy. Both would likely require a constitutional amendment to add these checks on the executive that are common in other democracies.

Loyola Law Schoolprofessors Karl Manheim andAllan Ideswrite that "the separation among the branches is not and never was intended to be airtight," and they point to the president's veto power as an example of the executive exercising legislative power. They also cite other examples of quasi-legislative and quasi-judicial power being exercised by the executive branch, as necessary elements of the administrative state, but they contend that ultimately all administrative power belongs to Congress rather than the President, and the only true "executive" powers are those explicitly described in the Constitution.[21]In this understanding, Manheim and Ides follow in the footsteps of Lessig and Sunstein.[2]

David J. Barron(now a federal judge) andMarty Ledermanhave also criticized the strong version of the unitary executive theory. They acknowledge that there is a compelling case for a unitary executive within the armed forces.[22]However, they argue that the Constitution does not provide for an equally strong unitary executive outside the military context, and they argue that theCommander in Chief Clausewould be superfluous if the same kind of unitary presidential authority resulted from the general constitutional provision vesting executive power in the president.[23]

Unlike the modern constitutions of many other countries, which specify when and how a state of emergency may be declared and which rights may be suspended, the U.S. Constitution itself includes no comprehensive separate regime for emergencies. Some legal scholars believe however that the Constitution gives the president inherent emergency powers by making him commander in chief of the armed forces, or by vesting in him a broad, undefined "executive power."[24]Congress has delegated at least 136 distinct statutory emergency powers to the president, each available upon the declaration of an emergency. Only 13 of these require a declaration from Congress; the remaining 123 are assumed by anexecutivedeclaration with no further congressional input.[25]Congressionally authorized emergency presidential powers are sweeping and dramatic and range from seizing control of the internet to declaring martial law.[24]This led the American magazineThe Atlanticto observe that "the misuse of emergency powers is a standard gambit among leaders attempting to consolidate power",[24]because, in the words of JusticeRobert H. Jackson's dissent inKorematsu v. United States,the 1944 Supreme Court decision that upheld theinternment of Japanese-Americans,each emergency power "lies about like a loaded weapon, ready for the hand of any authority that can bring forward a plausible claim of an urgent need."[24]

Background[edit]

Founding debate of one or multiple executives[edit]

The phrase "unitary executive" was discussed as early as thePhiladelphia Conventionin 1787, and referred only to having a single individual fill the office of president, as proposed in theVirginia Plan.The alternative was to have several executives or an executive council, as proposed in theNew Jersey Planand as promoted byElbridge Gerry,Edmund Randolph,andGeorge Mason.[26][27]

At the Pennsylvania ratifying convention in 1787,James Wilsonemphasized the advantages of a single chief executive, including greater accountability, vigor, decisiveness, and responsibility:

[T]he executive authority is one. By this means we obtain very important advantages. We may discover from history, from reason, and from experience, the security which this furnishes. The executive power is better to be trusted when it has no screen. Sir, we have a responsibility in the person of our President; he cannot act improperly, and hide either his negligence or inattention; he cannot roll upon any other person the weight of his criminality; no appointment can take place without his nomination; and he is responsible for every nomination he makes. We secure vigor. We well know what numerous executives are. We know there is neither vigor, decision, nor responsibility, in them. Add to all this, that officer is placed high, and is possessed of power far from being contemptible; yet not a single privilege is annexed to his character; far from being above the laws, he is amenable to them in his private character as a citizen, and in his public character by impeachment.[28]

In 1788, the pseudonymous letters of theFederal Farmerdefended the proposed unitary executive, arguing that "a single man seems to be peculiarly well circumstanced to superintend the execution of laws with discernment and decision, with promptitude and uniformity."[29]

Meanwhile,Federalistssuch asJames Madisonwere emphasizing an additional advantage of a unitary executive. InFederalist No. 51,he wrote that an undivided executive would strengthen the ability of the executive to resist encroachments by the legislature: "As the weight of the legislative authority requires that it should be thus divided [into branches], the weakness of the executive may require, on the other hand, that it should be fortified."[30]

Alexander Hamiltonlater pointed out that the Constitution grants executive power and legislative power in different ways, with the legislative powers of Congress being expressly limited to what is "herein granted," unlike executive powers which are not expressly limited by an enumeration. Hamilton wrote:

In the article which gives the legislative powers of the government, the expressions are "All legislative powers herein granted shall be vested in a congress of the United States." In that which grants the executive power, the expressions are "The executive power shall be vested in a President of the United States." The enumeration ought therefore to be considered, as intended merely to specify the principal articles implied in the definition of executive power....[31]

Judicial decisions[edit]

See also:Marbury v. Madison

In the 1926 case ofMyers v. United States,the United States Supreme Court decided that the president has the exclusive power to remove executive branch officials, and does not need the approval of the Senate or any other legislative body.[non-primary source needed]The court also wrote:

The ordinary duties of officers prescribed by statute come under the general administrative control of the President by virtue of the general grant to him of the executive power, and he may properly supervise and guide their construction of the statutes under which they act in order to secure that unitary and uniform execution of the laws which article 2 of the Constitution evidently contemplated in vesting general executive power in the President alone.[32]

Subsequent cases such asHumphrey's Executor v. United States(presidential removal of certain kinds of officers),United States v. Nixon(executive privilege), andBowsher v. Synar(control of executive functions) have flexed the doctrine's reach back and forth.Justice Scaliain his solitary dissent inMorrison v. Olsonargued for an unlimited presidential removal power of all persons exercising executive branch powers, which he argued included theindependent counsel;the court disagreed, but later moved closer to Scalia's position inEdmond v. United States.[33]

Growth of presidential powers[edit]

The power of the presidency has grown slowly over the decades due to key events and to Congress or the Courts not being willing to rein in presidential power. In addition, presidents rarely give up powers exercised by their predecessors.[34]

The Reagan era is cited as a major catalyst in growing presidential power,[34][35]with significant growth post-9/11 as conservatives have most readily embraced the idea of a unitary executive.[36][37]

Use in theClinton administrationwas criticized byElena Kaganin 2001.[38]

Dick Cheneyand theGeorge W. Bush administrationsupported the theory.[39]For example, Bush once wrote in a signing statement that he would, "construe Title X in Division A of the Act, relating to detainees, in a manner consistent with the constitutional authority of the President to supervise the unitary executive branch and as Commander in Chief and consistent with the constitutional limitations on the judicial power."[40]Critics acknowledge that part of the president's duty is to "interpret what is, and is not constitutional, at least when overseeing the actions of executive agencies," but critics accused Bush of overstepping that duty by his perceived willingness to overrule US courts.[41]During his confirmation hearing to become an associate justice on theUnited States Supreme Court,Samuel Alitoseemed to endorse a weaker version of the unitary executive theory.[42]

Donald Trump exerted the greatest control over the executive duringhis Presidencythan any other modern president, often citing Article II of the constitution.[34][43][44]Bill Barrnotably supported the theory before his confirmation as Attorney General in 2018 memo criticizing theRussia probe.[45][46]

Project 2025proposes using the theory as justification to give Trump or the next Republican president maximum control over the executive branch.[15][16][4]The 2024 Supreme Court ruling onTrump v. United Statescould make the president even more powerful, with some interpreting it as an endorsement of the Unitary Executive Theory by the six conservative justices.[47][48]

State governors[edit]

Unitary executive theory does not exist at the state level in the United States. In contrast to a single elected executive officer such as the president,plural executivesexist in several states where executive officers such aslieutenant governor,attorney general,comptroller,secretary of state,and others, are elected independently of thestate's governor.

The executive branches ofTexasandNorth Carolina,for example, maintain a plural executive whereby the chief executive's actions can be curbed by other elected executive officers. The group of North Carolina executive officers is known as theNorth Carolina Council of Stateand it wields fair amounts of statutory powers when approving monetary and property transactions by the state government.[49]

In film[edit]

In the 2018 biographical filmVice,directed byAdam McKay,the unitary executive theory is explored in some detail and dramatized.[10]Vice PresidentDick Cheney,the film's subject, his lawyerDavid Addington,deputy assistant attorney general in theOffice of Legal CounselJohn Yoo,and associate justiceAntonin Scaliafigure prominently in the theory's development and promotion. They brought it to the foreground of modern discussions on the topic of executive power beginning in 2001, continuing throughout theBush administrationand beyond. The application of this legal doctrine has implications for the prosecution of theWar on Terror,the subsequent2003 U.S. invasion of Iraq,the use ofenhanced interrogation techniquesat sites such asGuantanamo BayandAbu Ghraib,andmass surveillance.These are highlighted in the narrative.[citation needed]

See also[edit]

References[edit]

  1. ^abcChabot, Christine Kexel (2020-11-13)."Is the Federal Reserve Constitutional? An Originalist Argument for Independent Agencies".Notre Dame Law Review.
  2. ^abcdefLessig, Lawrence & Sunstein, Cass (1994)."The President and the Administration"(PDF).Columbia Law Review.94(1): 1–123.doi:10.2307/1123119.JSTOR1123119.
  3. ^Driesen, David (2020-11-01)."The Unitary Executive Theory in Comparative Context".UC Law Journal.72(1): 1.ISSN0017-8322.
  4. ^abcPilkington, Ed (2024-06-07)."Trump plots capture of DoJ in renewed assault on US justice system".The Guardian.ISSN0261-3077.Retrieved2024-07-11.
  5. ^Ornstein, Norman (June 26, 2007)."Blog: Cheney's chutzpah".The Economist.ISSN0013-0613.Retrieved2024-07-11.
  6. ^abDriesen, David (July 9, 2024)."The Unitary Executive Theory in Comparative Context".UC Law....centralization of head-of-state control over the executive branch of government provides a pathway to autocracy. Indeed, unilateral presidential control of the executive branch constitutes a defining characteristic of autocracy.
  7. ^abCalabresi, Steven & Rhodes, Kevin (1992). "The Structural Constitution: Unitary Executive, Plural Judiciary".Harvard Law Review.105(6): 1165.doi:10.2307/1341727.JSTOR1341727.
  8. ^Strauss, Peter L.(2024-03-05)."Overseer or" The Decider "? The American President in Administrative Law".Faculti.Retrieved2024-07-13.
  9. ^Dean, John (2007).Broken Government.Viking. p.102.ISBN9780670018208.unitary executive.
  10. ^abGreenberg, Jon."What Vice gets right and wrong about Dick Cheney".@politifact.Retrieved2024-07-11.
  11. ^Latham, Joshua (2000)."The Military Munitions Rule and Environmental Regulation of Munitions".Boston College Environmental Affairs Law Review.27.Boston, Massachisetts:Boston College:467.
  12. ^abcdBirk, Daniel D. (January 2021)."Interrogating the Historical Basis for a Unitary Executive".Stanford Law Review.45(6): 2177.doi:10.2307/1229142.ISSN0038-9765.As this Article shows, however, the unitarians' claims about the original meaning of the executive power are largely unfounded. The ability to remove executive officials was not one of the prerogative powers of the British Crown. Moreover, the King neither appointed nor was able to remove all of his principal officers, many of whom held their offices for life or pursuant to other forms of tenure and who operated independent of the King's direction or control.
  13. ^Shoenberger, A. (2021). The Unitary Executive Theory Is Plainly Wrong and Anti-American: “Presidents Are Not Kings.”Albany Law Review,85(4), 88–107.
  14. ^Nelson, Eric (July 9, 2024)."Justice Sotomayor was right for the wrong reasons".The Economist.ISSN0013-0613.Retrieved2024-07-11.
  15. ^abWendling, Mike (July 7, 2024)."Project 2025: A wish list for a Trump presidency, explained".BBC....a controversial idea known as 'unitary executive theory'
  16. ^abPengelly, Martin (2023-09-15)."US hard-right policy group condemned for 'dehumanising' anti-LGBTQ+ rhetoric".The Guardian.ISSN0261-3077.Retrieved2024-07-11.
  17. ^Ornstein, Norman (June 26, 2007)."Blog: Cheney's chutzpah".The Economist.ISSN0013-0613.Retrieved2024-07-11.
  18. ^Greenhut, Steven (2024-06-28)."Project 2025: The Heritage Foundation's plan to embrace bigger government during Trump's second term".Reason.Retrieved2024-07-11.But implementing what critics call "unitary executive theory" —i.e., putting all aspects of the federal government under the control of the president—is a prescription for authoritarianism and abuse.
  19. ^Tannehill, Brynn (July 24, 2023)."People Aren't Facing Up to the Horrors a New Trump Term Would Bring".The New Republic.ISSN0028-6583.Retrieved2024-07-11.
  20. ^Berry, Christopher & Gersen, Jacob (2008)."The Unbundled Executive".University of Chicago Law Review.Chicago, Illinois:University of Chicago.Archived fromthe originalon August 7, 2011.We certainly do not claim that the most sensible or even any plausible interpretation of the US Constitution establishes a plural unbundled executive; but perhaps it should
  21. ^Manheim, Karl; Ides, Allan (September 2006). "The Unitary Executive".Los Angeles Lawyer.SSRN943046.Loyola-LA Legal Studies Paper No. 2006-39.
  22. ^Barron, David; Lederman, Martin (2008)."The Commander in Chief at the Lowest Ebb: Framing The Problem, Doctrine, And Original Understanding".Harvard Law Review.121.Cambridge, Massachusetts:Harvard University:689. Archived fromthe originalon January 25, 2009.we think the text, as reinforced by historical practice, makes a strong case for at least some form of a 'unitary executive' within the armed forces, particularly as to traditional functions during armed conflicts.
  23. ^Barron, David; Lederman, Martin (2008)."The Commander in Chief at the Lowest Ebb: A Constitutional History".Harvard Law Review.121.Cambridge, Massachusetts:Harvard University:941. Archived fromthe originalon January 24, 2009.there are those who would argue that the 'unitary executive' must have effective control over all Article II functions, in which case the superintendence guaranteed by the Commander in Chief Clause would not appear to do any additional work with respect to superintendence.
  24. ^abcdGoitein, Elizabeth (January–February 2019)."The Alarming Scope of the President's Emergency Powers".The Atlantic.Archived fromthe originalon April 1, 2020.Retrieved1 April2020.
  25. ^"A Guide to Emergency Powers and Their Use".Brennan Center for Justice at New York University School of Law.Archived fromthe originalon April 1, 2020.RetrievedJanuary 7,2019.
  26. ^Ketchum, Ralph, ed. (1986).The Anti-Federalist Papers and the Constitutional Convention Debates.Signet Classic. p. 67.Mr. [James] Wilson entered into a contrast of the principal points of the two plans [i.e. the Virginia Plan and the New Jersey Plan]... These were... A single Executive Magistrate is at the head of the one—a plurality is held out in the other.
  27. ^"Records of the Federal Convention, Article 2, Section 1, Clause 1".The Founder's Constitution.1787.
  28. ^Wilson, James (December 4, 1787)."Pennsylvania Ratifying Convention".
  29. ^Ellis, Richard (1999).Founding the American Presidency.Lanham, Maryland:Rowman & Littlefield.p. 39.ISBN9780847694990.
  30. ^Madison, James (February 6, 1788)."Federalist no. 51".
  31. ^Hamilton, Alexander(June 29, 1793)."Pacificus Letters, No. 1".
  32. ^Myers v. United States,272 U.S. 52(1926).
  33. ^Calabresi, Steven & Lawson, Gary (2007)."The Unitary Executive, Jurisdiction Stripping, and the Hamdan Opinions: A Textualist Response to Justice Scalia"(PDF).Columbia Law Review.107:1002–1047. Archived fromthe original(PDF)on 6 March 2009.
  34. ^abcThunberg, Michael E. (2021-12-01)."The Unitary Executive Theory: A Danger to Constitutional Government".Political Science Quarterly.136(4): 770–771.doi:10.1002/polq.13274.ISSN0032-3195.
  35. ^Mosley, Tonya (December 14, 2023)."Why a second Trump administration may be more radical than the first".Fresh Air on NPR.
  36. ^Rosen, Jeffrey (July 2, 2024)."Immunity ruling continues a trend of expanding presidential power, scholar says".NPR.
  37. ^Krotoszynski, Ronald (December 10, 2020)."The Conservative Idea That Would Let Biden Seize Control of Washington".Politico.
  38. ^Mears, Bill (May 10, 2010)."High court contender Kagan brings reputation for consensus-building - CNN".cnn.Retrieved2024-07-11.
  39. ^Johnsen, Dawn(April 2008)."What's a President To Do? Interpreting the Constitution in the Wake of Bush Administration Abuses"(PDF).Boston University Law Review.88:395.On 363 occasions, President Bush objected to provisions that he found might conflict with the president's constitutional authority 'to supervise the unitary executive branch.'
  40. ^Lazarus, Edward (January 5, 2006)."How Much Authority Does the President Possess When He Is Acting as 'Commander in Chief'? Evaluating President Bush's Claims Against a Key Supreme Court Executive Power Precedent".FindLaw.That signed statement shows, in microcosm, how the President sees the separation of powers: The President, in his view of the world, can interpret away constraints on his power, such as those in the McCain Amendment, or FISA before it. And the courts can hardly question his dubious 'interpretations' even if they gut the very statutes they construe: After all, there are 'constitutional limitations on the judicial power'—though not, apparently, on the power of the executive.
  41. ^Van Bergen, Jennifer (January 9, 2006)."The Unitary Executive: Is The Doctrine Behind the Bush Presidency Consistent with a Democratic State?".Findlaw.In his view, and the view of his Administration, that doctrine gives him license to overrule and bypass Congress or the courts, based on his own interpretations of the Constitution....
  42. ^Liptak, Adam(2006)."Few Glimmers of How Conservative Judge Alito Is".The New York Times.p. A1.Retrieved2 November2017.
  43. ^Dodds, Graham G. (2023), Akande, Adebowale (ed.),"Is the President a King? The Unitary Executive Theory and the Presidency of Donald J. Trump",U.S. Democracy in Danger: The American Political System Under Assault,Cham: Springer Nature Switzerland, pp. 487–517,doi:10.1007/978-3-031-36099-2_21,ISBN978-3-031-36099-2,retrieved2024-07-12
  44. ^Crouch, Jeffrey; Rozell, Mark J.; Sollenberger, Mitchel A. (2020).The Unitary Executive Theory: A Danger to Constitutional Government.University Press of Kansas.doi:10.2307/j.ctv1ft83xf.ISBN978-0-7006-3004-2.
  45. ^McCarthy, Tom (2019-01-13)."Trump's attorney general pick raises fears of a president above the law".The Guardian.ISSN0261-3077.Retrieved2024-07-11.
  46. ^Deconstructed (2020-05-21)."Deconstructed Podcast: Is Bill Bar the Most Dangerous Trump Official?".The Intercept.Retrieved2024-07-11.
  47. ^The Project 2025 plan and Trump's links to its authors.PBS News Hour. July 9, 2024.Retrieved2024-07-11.
  48. ^Tucker, Eric (July 2, 2024)."Supreme Court opinion conferring broad immunity could embolden Trump as he seeks to return to power".Associated Press.'This is a full-throated endorsement of the unitary executive theory' in a dramatic way, said Cornell University law professor Michael Dorf, referring to the theory that the U.S. Constitution gives the president expansive control over the government's executive branch.
  49. ^"North Carolina State Government - The Executive Branch - Council of State".carolana.Retrieved2021-04-30.

Further reading[edit]

External links[edit]

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