1. William W. Bibb introduced the resolution in the Senate on 2 Apr. 1814. The same day, in the course of arguing against Christopher Gore’s resolutions challenging the recess appointments of Gallatin, Adams, and Bayard (see Monroe to JM, 28 Mar. 1814, n. 2), Outerbridge Horsey presented a list of nineteen such appointments made by preceding administrations to newly established diplomatic positions. Most of these were included in the tables submitted by Monroe (2 pp.; printed in ASP, Miscellaneous, description begins American State Papers: Documents, Legislative and Executive, of the Congress of the United States … (38 vols.; Washington, 1832–61). description ends 2:243–44), which listed twenty-seven ministerial and secretarial recess appointments, nineteen of which were for positions being filled for the first time under the federal Constitution, and sixty-six consular and commercial agent recess appointments, of which twenty-six were for positions never previously filled. Answering the arguments of his opponents on 12 Apr., Gore undertook to demonstrate that several of the Washington appointments on the lists were made under circumstances that disqualified them as precedents for JM’s appointments of Gallatin, Adams, and Bayard, and dismissed as unconstitutional those made during John Adams’s and Thomas Jefferson’s administrations. Evidently less than overwhelmed by these efforts, Gore’s fellow senators thereupon postponed consideration of his resolutions until the next session of Congress (Annals of Congress, description begins Debates and Proceedings in the Congress of the United States … (42 vols.; Washington, 1834–56). description ends 13th Cong., 2d sess., 705–22, 740–59).

2. The enclosures have not been found, but for the commissions, see PJM-PS, description begins Robert A. Rutland et al., eds., The Papers of James Madison: Presidential Series (7 vols. to date; Charlottesville, Va., 1984–). description ends 6:210 n.