I think it's important to understand what led to the Scotus ruling. Since the Senate makes its own rules, those rules allow one senator to keep the Senate in session. To thwart the President's recess nomination opportunities, the Republicans would send one of their own Senators to the Senate every three days or so to give a speech or conduct some brief, simple business. Thus, technically, the Senate would remain in session. The Court adopted a strict construction approach to come to this ruling.