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the Senate has taken measures from time to time to prevent a president from making recess appointments, specifically by holding pro forma sessions. The Supreme Court affirmed that pro forma sessions are sufficient to prevent recess appointments and addressed other intricacies of the practice in NLRB v. Noel Canning
The term pro forma (Latin for "as a matter of form" or "for the sake of form") is most often used to describe a practice or document that is provided as a courtesy or satisfies minimum requirements, conforms to a norm or doctrine, tends to be performed perfunctorily or is considered a formality. The term is used in legal and business fields to refer to various types of documents that are generated as a matter of course.
https://en.wikipedia.org/wiki/Pro_forma#United_States