A federal appeals court has ruled President Obama violated the Constitution in making recess appointments to the National Labor Relations Board a year ago. Obama filled three vacant NLRB positions to avoid a suspension of its operations after Republicans refused to confirm his nominees. But on Friday a three-judge panel ruled Obama had improperly asserted that the Senate was in recess even though it was technically in “pro forma” sessions. If upheld, the ruling could bring an end to the practice of recess appointments for all future presidents.