Presidents Obama and Biden have taken military actions without prior Congressional approval multiple times. Obama authorized interventions in Libya (2011) and against the Islamic State (2014), citing existing AUMFs or limited scope. Biden ordered airstrikes in Yemen (2024) and against Iran-backed groups, justifying them under Commander-in-Chief powers. Exact counts are debated due to varying definitions of "military action," but at least several instances occurred under each. The issue remains contentious, with legal scholars split on constitutional limits versus executive authority.