Expect the Dems to somehow create extended recesses under the next GOP Prez.
I think you mean the reverse of that, absence of a recess results in absence of power to recess appoint.
The DEMs started the practice of phony Congressional session, so the books look as though Congress is in session (not in recess) when it is actually not in session. They'd keep two people in DC, one to sit in the high chair, and one to open and close the session. I think the average time of being in session was about 30 seconds.
SCOTUS punted this too. The president and Congress have been allowing unconstitutional recess appointments for over a hundred years. SCOTUS says, well, if it's been going on that long, "poof," it's constitutional.