Since he's been in office, President Obama has issued 195 executive orders and 231 “presidential memorandums.”

Critics say that by using the memos, Obama and his advisers can claim the president is not over-using executive orders.

On "America's Newsroom" today, Judge Andrew Napolitano said there is no legal definition for "memorandum."

"Why is he changing the terminology?" Judge Nap asked. "Because we in the media have been telling the public how many times he's doing this and he's trying to obfuscate." reported:

According to USA Today, when the memos and executive orders are combined, Obama is on pace to issue more “high-level executive actions” than any president since Harry Truman.

As noted in the review, Obama’s most controversial executive action of late – an overhaul of the U.S. immigration system including de facto legal status for up to 5 million illegal immigrants – was done through memoranda.

Those actions already have led to legal challenges – and one judicial rebuke. On Tuesday, U.S. District Court Judge Arthur Schwab, in Pennsylvania, issued an opinion claiming some of Obama’s actions were unconstitutional.

The opinion, though, was delivered in a case not directly related to those actions, and the Justice Department downplayed Schwab’s opinion as “unfounded” and “flatly wrong.”

According to the USA Today review, Obama has used memoranda to take a number of other actions, including directing the Labor Department to collect salary data from federal contractors to see what they’re paying women and minorities, and directing federal law enforcement agencies to trace firearms that are part of federal probes.

The differences between an order and a memorandum are slight. According to the USA Today review, executive orders are numbered and memoranda are not. Executive orders have to cite the law they’re based on, and memoranda do not. Both actions can be used for similar purposes, though.

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