The Constitution does not define the term "inferior officers," but it would appear that in this class are included all officers subordinate or inferior to those officers in whom other appointments may be vested.4 The point has never been squarely passed upon by the court since Congress has never attempted to regulate the appointment to any but distinctively subordinate and inferior positions. Should it attempt to determine by law the appointment of heads of the great departments, or even of the heads of bureaus and divisions and commissions, or even of important local officers, such as revenue officers or postmasters in the larger cities, the constitutionality of the law would undoubtedly be subjected to judicial examination.
3 See ante, section 231 for further discussion of what constitutes an "office" within the meaning of the Constitution.
4 Collins v. United States. 14 Ct. of Claims, 569.