On July 30, 2013, the United States Senate confirmed all five nominees of the President to terms of service on the National Labor Relations Board. The five members include Chairman Mark Pearce who was serving a term set to expire on August 27 of this year. The Senate also confirmed Nancy Schiffer, a former attorney for the United Auto Workers and the AFL-CIO and Kent Hirozawa, a former staff attorney for the NLRB, private practitioner representing labor unions and Senior Counsel to Mark Pearce. Finally, the Senate confirmed Harry Johnson III and Philip Miscimarra who previously represented management in labor matters. Without action from the Senate the NLRB would have dropped to two members later this month and would not constitute a quorum upon the expiration of the term of Chairman Mark Pearce. The NLRB also faced criticism regarding recess appointees Richard Griffin and Sharon Block who were appointed during pro forma sessions of the Senate in January of 2012. Their appointments have been ruled constitutionally invalid by the Circuit Court of the District of Columbia, and that decision is currently under review by the United States Supreme Court.