The Puzzle of Hamilton's Federalist No. 77:

The Puzzle of Hamilton's Federalist No. 77: It Turns out Hamilton was Right After All, by Seth Barrett Tillman, abstract of an upcoming article, Harvard Journal of Law and Public Policy, Vol. 33, pp. 1-15, 2010

This is the enigmatic great white whale among Founding-era documents.

Partisans of Senate (or congressional power) agree with Hamilton (or, at least, they think they agree with Hamilton). These commentators look back to the Tenure in Office Act and to any number of statements made on the floor of the House when statutory removal was first debated in 1789 -- all purportedly consistent with Hamilton's statement here. Partisans of presidential power disagree with Hamilton (or, at least, they think they do). They affirm that Hamilton erred. These commentators look to Myers v. United States [272 U.S. 52 (1926)] and to statements made by Madison on the floor of the House during the statutory removal debates. The consensus view, nay - the universal view, is that Hamilton was speaking to the issue of the "removal" of federal officers.