Twenty-second Amendment to the United States Constitution
As worded, the primary focus of the 22nd Amendment is on limiting individuals twice elected to the presidency from being elected again. Due to this, several issues could be raised regarding the amendment's meaning and application, especially in relation to the 12th Amendment, ratified in 1804, which states, "But no person constitutionally ineligible to the office of President shall be eligible to that of Vice-President of the United States". While it is clear that under the 12th Amendment the original constitutional qualifications of age, citizenship, and residency apply to both the president and vice president, it is unclear whether someone who is ineligible to be elected president could be elected vice president. Because of this apparent ambiguity, there may be a loophole in the 22nd Amendment whereby a two-term former-president could be elected vice president and then succeed to the presidency as a result of the incumbent's death, resignation, or removal from office (or even succeed to the presidency from some other stated office in the presidential line of succession).
Michelle Obama
Over the course of the Obama presidency, particularly during the second term, Michelle Obama was subject to speculation over whether she would run for the presidency herself, similarly to predecessor Hillary Clinton. A potential Michelle Obama candidacy was supported by both Samuel L. Jackson and James Clyburn. On April 6, 2009, CNN did a poll on whether she should run for the presidency in 2020, 83% of responders being opposed to the idea. A May 2015 Rasmussen poll found Obama had 22% of support to Clinton's 56% of winning the Democratic nomination, higher than that of potential candidates Elizabeth Warren, Martin O'Malley and Bernie Sanders. Another poll from that month found 71% of Americans believed that Obama should not run for the presidency, only 14% approving. On January 14, 2016, during a town-hall meeting, President Obama was asked if the First Lady could be talked into running. He responded, "There are three things that are certain in life: death, taxes, and Michelle is not running for president. That I can tell you." On March 16, 2016, while speaking in Austin, Texas, Obama denied that she would ever run for the office, citing a desire to "impact as many people as possible in an unbiased way". In the Epilogue to her November 13, 2018 Becoming (book) Obama writes "I have no intention of running for office, ever" recognizing that "politics can be a means for positive change, but this arena is just not for me."