On January 4, 2012, Obama announced recess appointments to three seats on the board: Sharon Block, Terence F. Flynn, and Richard Griffin. The appointments were criticized by Republicans, including the House Speaker John Boehner, as unconstitutional and "a brazen attempt to undercut the role of the Senate to advise and consent the executive branch on appointments". Although made as recess appointments, critics questioned their legality, arguing that Congress had not officially been in recess as pro forma sessions had been held. Former U.S. attorney general Edwin Meese stated that in his opinion, since the appointments were made when the Senate was "demonstrably not in recess", they represented "a constitutional abuse of a high order". On January 12, 2012 the U.S. Justice Department released a memo stating that appointments made during pro forma sessions are supported by the Constitution and precedent.