So if a president can't undo any executive order of a previous administration, Which is what SCOTUS told us with their DACA decision. That means the president can now issue any executive order he wants and make it lasting law, as long as it's constitutional, and that can't be overturned without action from the SCOTUS. So it would appear that POTUS can just bypass congress entirely, Just as Barry Sotoro Hussein Soweto Obama did.