Morrison v. Olsen, 487 U.S. 654 (1988), was a landmark case that dealt with the constitutionality of the Independent Counsel provision of the Ethics in Government Act of 1978. The act was enacted in response to the [[Watergate]] scandal, aiming to ensure independent investigations of high-ranking government officials when conflicts of interest may arise. The case arose when an independent counsel, Alexia Morrison, was appointed to investigate whether Assistant Attorney General Theodore B. Olson had provided false testimony to [[Congress]]. Olson, along with other parties, challenged the constitutionality of the Independent Counsel provision, arguing that it violated the Appointments Clause (Article II, Section 2, Clause 2) and the [[separation of powers]] doctrine under the U.S. [[Constitution]]. The Appointments Clause sets forth the process for appointing officers of the United States. Olson contended that the appointment of independent counsels violated this clause, as they were not appointed by the President and confirmed by the [[Senate]], nor were they considered "inferior officers" exempt from this process. [[The Supreme Court]], in a 7-1 decision, upheld the constitutionality of the Independent Counsel provision. Writing for the majority, Chief Justice William Rehnquist held that independent counsels were "inferior officers" and could be appointed by the judiciary without violating the Appointments Clause. Furthermore, the Court determined that the provision did not infringe on the President's executive power or the Separation of Powers doctrine, as it allowed for sufficient executive control over independent counsels, and it served an important function in preventing conflicts of interest in investigations involving high-level government officials. Justice [[Antonin Scalia]] dissented, arguing that the Independent Counsel provision violated the Appointments Clause and the Separation of Powers doctrine, as it stripped the President of his authority to control the prosecutorial function and transferred that power to the judiciary. Although the Independent Counsel provision was upheld in Morrison v. Olsen, it was later allowed to expire in 1999 and was replaced by the Department of Justice's appointment of Special Counsels, who operate under different rules and regulations.