With Donald Trump back in the White House and the Senate under GOP control, speculation abounds that he could name a fourth Justice to the US Supreme Court (Yale University Press, Newsweek, Time). An announced retirement effective upon the confirmation of a successor will count, irrespective of the date it is to take effect (e.g., Supreme Court - O'Connor Letter, Supreme Court - Breyer Letter). The death or removal of a Justice alone will not count.

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