Obama and Bush did it...
" Trump would hardly be the first president to deploy the recess appointment. Former President Barack Obama made 32 such appointments and his immediate predecessor, George W. Bush made 171, according to the Congressional Research Service."
https://www.bloomberg.com/news/newsletters/2024-11-11/trump-wants-senate-gop-to-give-him-a-freer-hand-on-appointments?srnd=homepage-asia
