[derisgun]

During the Bush administration Senate Majority Leader Harry Reid used pro forma sessions to block recess appointments. According to uslegal.com Pro forma sessions are meetings held ‘in form only.’ As used in parliamentary law, it refers to a legislative session held not to conduct business but to satisfy a constitutional provision that neither house may adjourn for longer than a certain time without the other house's consent. In the U.S., either house of the United States Congress the can hold a pro forma session. During these sessions no votes are held and no legislative business is conducted. The session "in form only" is held for purposes of meeting the 3-day rule in the Constitution. The three day rule requires each House to gain the permission of the other for recesses longer than 3 days. When the permission is not forthcoming, or not requested in time, the affected chamber convenes briefly with hardly anyone in attendance and then adjourns. Pro forma sessions can also be used to prevent the President from making recess appointments, pocket-vetoing bills, or calling the Congress into special session.

http://definitions.uslegal.com/p/pro-forma-session/

It appears that the recent recess appointment may have violated the Constitution according to John C. Eastman, a professor at Chapman University School of Law, and an expert on the constitutional separation of powers.

“They’re ignoring that the recess clause was designed to fill vacancies that occurred during the recess. These did not. They are ignoring entirely Section 5, Article 1,” Eastman told CNSNews.com. “The Senate doesn’t have the authority to recess without the House’s approval even if they wanted to.

Also, legitimacy will be questioned, said Russell Weaver, a professor at the Louis D. Brandeis School of Law at the University of Louisville.

“My guess is the president’s action is illegal,” Weaver told CNSNews.com. “You can be confident there will be a court challenge the first time this newly, allegedly appointed director takes an action where money is involved. I don’t think there is any doubt this will end up in the courts and go on for years. If it’s struck down, it would undermine everything that’s done in the meantime.”
Both the executive and legislative branches – and both parties – have historically exceeded their roles in the appointment process, said Bob Turner, a professor at the University of Virginia School of Law.

I anticipate there will be court challenge.