Sandra Day O'Connor could re-join the court without Senate Confirmation, since she already has life-time tenure, and is on Senior Status. This would spare the country a bruising confirmation battle during the presidential election year, and restore the Court to full membership of 9 Justices. She could, if she wishes, leave the court again in Summer of 2017 at the end of the 2016-17 term, and allow the next president to appoint another replacement for Scalia.
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