Can Erika McEntarfer sue trump for libel?

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6. The FTC case is dissimilar.

The statute creating the FTC expressly provides that an FTC Commissioner can only be removed for cause. As the District Court stated in the case brought by Slaughter, in order "to insulate the agency from volatile political headwinds that might jeopardize its mission, Congress placed restrictions on the selection and tenure of FTC Commissioners, including a requirement that they only be removed for “inefficiency, neglect of duty, or malfeasance in office.” 15 U.S.C. § 41.

Compare that to the statutory provision establishing the position of Commissioner of Labor Statistics:

29 U.S. Code § 3 - Commissioner; appointment and tenure of office; compensation:The Bureau of Labor Statistics shall be under the charge of a Commissioner of Labor Statistics, who shall be appointed by the President, by and with the advice and consent of the Senate; he shall hold his office for four years, unless sooner removed, and shall receive a salary.

Unlike the FTC, Congress placed no restrictions on the removal of the Commissioner from office.