Nevertheless, presidents have frequently used recess appointments to circumvent the possibility that the Senate may reject the nominee. Furthermore, as the Supreme Court held in Myers v. United States, although the Senate's advice and consent is required for the appointment of certain executive branch officials, it is not necessary for their removal.[64][65] Recess appointments have faced a significant amount of resistance and in 1960, the U.S. Senate passed a legally non-binding resolution against recess appointments.[citation needed]