An expert Q&A with Harold P. Coxson of Ogletree Deakins Nash Smoak & Stewart P.C. on the US Court of Appeals for the District of Columbia Circuit's January 25, 2013 decision in Noel Canning v. NLRB. In that case, the DC Circuit ruled that President Obama's January 4, 2012 recess appointments to the National Labor Relations Board (NLRB) were invalid and vacated a challenged NLRB decision for lack of a three-member quorum.