characterized his agency's recommendation as unprecedented, adding, "You know what else is unprecedented? Kellyanne Conway’s behavior." Due to Conway's status as a presidential appointee, the OSC was unable to take any steps to implement its recommendation, but it was submitted to the President for consideration. The White House immediately rejected the finding and demanded that it be withdrawn by the OSC. Trump said he thought the recommendation was "very unfair, it's called freedom of speech." On June 26, 2019, Conway did not appear at a hearing by the House Committee on Oversight and Reform, leading that committee to issue a subpoena for her. At that hearing, Special Counsel Henry Kerner testified that Conway had been found guilty of two Hatch Act violations in 2018 and 11 in 2019. In comparison, during the eight years of the Obama administration, only two federal employees were found guilty of violating the Hatch Act, with one violation each. Michael Flynn comments and week-long suspension from television On February 13, 2017, Conway claimed that former national security advisor Michael Flynn had the president's "full confidence". Hours later, Flynn resigned. The following day, Conway claimed Flynn had offered to resign, but White House Press Secretary Sean Spicer said Trump had asked Flynn for his resignation. It was then reported that Conway had allegedly leaked negative stories about Spicer to the press. Conway came under widespread criticism because her comments about Flynn had been so inaccurate. On February 15, 2017, Washington Post columnist Jennifer Rubin said Conway should be banned from future television appearances. "In recent days, George Stephanopoulos and Matt Lauer blasted her directly, essentially calling her a fabulist. Given all that, it would be irresponsible for any news show to put her out there, suggesting she really does not know what is going on at any given moment", Rubin wrote. Also on February 15 the MSNBC news show Morning Joe officially banned her from future appearances. The show's primary host Joe Scarborough said the decision to ban Conway from the show was based on her being "out of the loop" and "in none of the key meetings". He added "She's not briefed. She's just saying things just to get in front of the TV to prove her relevance." The show's co-host Mika Brzezinski said, "I don't believe in fake news, or information that is not true... every time I've ever seen her on television, something's