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January 25, 2013 CONNECT WITH SMARTBRIEF Share | Sign up | Archive | Advertise National Pulse  Appeals court nixes Obama's recess appointments    Obama/Reuters A three-judge panel at the U.S. Court of Appeals for the D.C. Circuit today ruled that President Barack Obama violated the Constitution when he made appointments to the National Labor Relations Board last year. The president has the authority to make appointments without Senate consent when that body is not is session. However, the Senate was not officially out of session when these appointments were made. The decision, if upheld, casts doubt on the validity of hundreds of NLRB decisions, as well as other recess appointments made by the president. The New York Times (tiered subscription model) (1/25) , The Washington Post/The Associated Press (1/25)      Reader Polls  This week's poll results: Obama 2.0 This week we asked you to identify what you thought to be the top priority for President Obama's second term.  By a wide margin, respondents chose "improving the economy and creating jobs," with tax reform a distant second.  Some readers wrote in asking for an option to include more than one answer.  Others accused us of promoting an anti-gun agenda by including "reducing gun violence" among the choices.  One reader suggested "immigration reform" as a priority. Still others suggested "balancing the budget," "reducing the deficit," or "reducing the size of government," all of which are under discussion in the ongoing budget negotiations. Next week: Women in combat. Improving the economy and creating jobs  43.40% Tax reform  20.64% Social Security and Medicare reform  13.89% Infrastructure investment  5.39% None of the above/other  5.02% Global climate change  4.28% Reducing gun violence  2.67% Energy independence  2.42% Improving education  2.29% Agenda Items  Obama names McDonough new chief of staff    McDonough/Reuters President Barack Obama today appointed deputy national security adviser Denis McDonough to be his next chief of staff. The decision to promote a longtime aide shows the premium Obama places on familiarity and loyalty, observers say. The move also puts a foreign-policy expert in the key position for the first time since Obama won re-election. The New York Times (tiered subscription model) (1/25) , The Wall Street Journal (1/25) , The Atlantic online (1/25)      Jindal to GOP: "Stop being the stupid party" National Journal (1/25)      Gerrymandering and the electoral college The Washington Post (1/24)      GOP no longer has debt-ceiling leverage, Geithner says Politico (Washington, D.C.) (1/25)      Sen. Saxby Chambliss of Georgia won't run in 2014 The Atlanta Journal-Constitution (1/25)      Data Points  Romney's Chrysler ad still doesn't stand up to scrutiny    Reuters Mitt Romney's former strategy chief, Stuart Stevens, has been asking fact-checkers to take a second look at a much-criticized ad in which the Romney campaign asserted that Chrysler was shifting production to China. Stevens argues that subsequent developments have shown the ad to be correct, but The Washington Post's fact-checkers say that's not the case. "With all due respect to Stevens, the claim that Romney turned out to be right is simply not accurate," writes Glenn Kessler. The Washington Post/The Fact Checker blog (1/25)      The Conversation  Ex-Gov. Jeb Bush: 8 hard truths about immigration policy The Wall Street Journal (1/24)      Editorial: Allowing women in combat roles acknowledges reality USA Today (1/24)      Lt. Gen. (Ret.) Jerry Boykin: Don't put women on the front lines USA Today (1/24)      Columnist Charlie Cook: Lawmakers lack the stomach for tough votes National Journal (1/25)      Daily Chuckle  Obama swings and misses in housefly rematch    Obama/Reuters President Barack Obama was strafed by a fly while announcing Mary Jo White's nomination as SEC chief -- but failed to show the killer instincts he displayed during a 2009 interview. This time round, the fly got the better of the president, even briefly landing on his face. "This guy is bothering me here," Obama complained. The Washington Post/Post Politics blog (1/24)      SmartQuote  Perfect freedom is as necessary to the health and vigor of commerce as it is to the health and vigor of citizenship." --Patrick Henry, American attorney and politician        SmartBrief delivers need-to-know news in over 100 targeted email newsletters to over 3 million readers. All our industry briefings are FREE and open to everyone—sign up today! 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