I just found this from Sai Prakash in "Regulating Presidential Powers," 2005: "In New Light on the Decision of 1789 (forthcoming July 2006), I argue that the removal debates do not reveal the existence of any majority clearly opposed to ***congressional regulation*** of the removal power."

2/ So Justice Barrett, when exactly did we "liquidate" that the president has an unconditional, indefeasible removal power? The unitary theorists are more like liquid than showing liquidation, changing as the Overton Window moves: Prakash, "Regulating Presidential Powers," 2005:

3/ You can read it for yourself here, contradicting the unitary executive theory on removal. When the argument shifted from 2005 to 2023 ("Executive Power of Removal"), he offered no contrary evidence for indefeasibility that stands up to scrutiny. files01.core.ac.uk/download/pdf...

4/ Prakash 2006: "B/c the logic of [executive power] did not necessarily preclude the idea of a default power, & b/c there was neither much discussion of the idea nor a decisive vote against it, the Decision of 1789 did not endorse the view that Congress lacked authority to modify [pres removal]."