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Presidential unilateral action has seen increasing prominence and importance, yet we have scant theory to explain its use. I present a model that incorporates a President, Congress, and Bureaucracy. The model demonstrates that Congressional position-taking could account for an increase in unilateral action: Congress can attempt to achieve the policy goals it shares with the President while nevertheless giving the appearance of recalcitrance. Dynamic considerations are also explored, including the long-term incentives of a bureaucracy whose ideal point is initially unknown.