Bill Clinton was criticized for some of his presidential pardons and acts of executive clemency. Pardoning or commuting sentences is a power granted by the Constitution to sitting U.S. presidents. Scholars describe two different models of the pardons process. In the 'agency model' of pardons the process is driven by nonpolitical legal experts in the Department of Justice. In contrast, Clinton followed the 'presidential model', viewing the pardon power as a convenient resource that could be used to advance specific policy goals. While Clinton pardoned a large number (450) of people compared with his immediate one-term predecessor Republican George H. W. Bush, who pardoned only 75, the number of people pardoned by Clinton was comparable to that pardoned by two-term Republican Ronald Reagan and one-term Democrat Jimmy Carter, who pardoned 393 and 534 respectively. However, Clinton chose to make nearly a third of his pardons on January 20, 2001, his last day in office. This was ridiculed as "Pardongate". In particular, Clinton's pardon of Marc Rich was investigated by Federal prosecutor Mary Jo White. She was later replaced by Republican James Comey, who found no illegality on Clinton's part. FALN Commutation of 1999 On August 11, 1999, Clinton commuted the sentences of 16 members of FALN, a Puerto Rican paramilitary organization that set off 120 bombs in the United States, mostly in New York City and Chicago. There were convictions for conspiracy to commit robbery, bomb-making, and sedition, as well as firearms and explosives violations. The 16 were convicted of conspiracy and sedition and sentenced with terms ranging from 35 to 105 years in prison. Clinton offered clemency on the condition that the prisoners renounce violence, seeing as none of the 16 had been convicted of harming anyone and they had already served 19 years in prison. This action was lobbied for by ten Nobel Laureates and the Archbishop of Puerto Rico. The commutation was opposed by the U.S. Attorney's Office, the FBI, and the Federal Bureau of Prisons and was criticized by many, including former victims of FALN terrorist activities and the Fraternal Order of Police. Hillary Clinton, then campaigning for her first term in the Senate, initially supported the commutation, but withdrew her support three days later. Congress condemned this action by President Clinton, with votes of 95–2 in the Senate and 311–41 in the House. The U.S. House Committee on Government Reform held an investigation on the