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In a January 30, 2008, editorial, the New York Times declared, "Over the last seven years, Mr. Bush has issued hundreds of these insidious documents declaring that he had no intention of obeying a law that he had just signed."<ref>[http://www.nytimes.com/2008/01/30/opinion/30wed1.html]"The Fine Print", NY Times, January 30, 2008</ref>
The use of signing statements that fall in to the "consitutional" category can create conundrums for executive branch employees. Political scientist James Pfiffner has written: <blockquote>"The president is the head of the executive branch, and in general, executive branch officials are bound to follow his direction. In cases in which a subordinate is ordered to do something illegal, the person can legitimately refuse the order. But if the public administrator is ordered to refuse to execute the law ... because the president has determined that the law infringes on his own interpretation of his constitutional authority, the public administrator faces an ethical dilemma."<ref>{{cite journal
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