I disagree it's as obvious as you think. He could run for VP and then act as de-facto President. It says that "No person shall be elected to the office of the P

I disagree it's as obvious as you think. He could run for VP and then act as de-facto President. It says that "No person shall be elected to the office of the President more than twice" - in that case, he would have been _elected_ Vice President, not President. And as as far as the 12th Amendment goes, "But no person constitutionally ineligible to the office of President shall be eligible to that of Vice-President of the United States." The 22nd amendment doesn't explicitly say he cannot serve as President, it just says "no person shall be _elected_ to the office of President". Yes, the spirit of the constitution clearly prevents a 3rd term, but it could be possible to employ a very literal interpretation that allows the above.