He used a recess appointment, acting while Congress is away to bypass Senate opposition.

NPR: Ambassadors React to Bolton Appointment

His appointment as Commissioner in September 2011 followed a period as Acting Commissioner in the period after his predecessor Sir Paul Stephenson's resignation.

BBC: Metropolitan Police faces ?500m 'cuts challenge'

The media didn't challenge the appointment of Zander buddy Tom Meredith , a board member, as acting CFO and some reported it as a bold move to action.

FORBES: Adviser Soapbox

Acting in the national interest, Mr. Bush gave Mr. Reich a recess appointment on Jan. 11, allowing him to serve without Senate confirmation until the end of this year.

CENTERFORSECURITYPOLICY: Now, confirm Secretary Reich