principal articles implied in the definition of executive power. ... In other words, the principle of expressio unius may be more applicable as a limitation upon congressional power than upon executive power. According to Hamilton, the unenumerated executive powers that are vested solely in the President "flow from the general grant of that power, interpreted in conformity with other parts of the Constitution, and with the principles of free government." Those other parts of the Constitution include the extensive powers granted 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 the Necessary and Proper Clause grants 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 also grants Congress power "To make Rules for the Government and Regulation of the land and naval Forces." The theory of the unitary executive can only be legitimate insofar as it allows Congress to wield its constitutional powers while ensuring that the President can do the same. Judicial decisions In the 1926 case of Myers 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. 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. Subsequent cases such as Humphrey's Executor v. United States (Presidential removal of certain kinds of officers), United States v. Nixon (executive privilege), and Bowsher v. Synar (control of executive functions) have flexed the doctrine's reach back and forth. Justice Scalia in his solitary dissent in Morrison v. Olson argued for an unlimited presidential removal power of all persons exercising executive branch powers, which he argued included the independent