Gentlemen of the Senate:
I was led by a consideration of the qualifications of William Patterson, of New Jersey, to nominate him an associate justice of the Supreme Court of the United States. It has since occurred that he was a member of the Senate when the law creating that office was passed, and that the time for which he was elected is not yet expired. I think it my duty, therefore, to declare that I deem the nomination to have been null by the Constitution.
George Washington, Special Message Online by Gerhard Peters and John T. Woolley, The American Presidency Project https://www.presidency.ucsb.edu/node/203160