 The statute authorizing the award was also criticized for apparently violating procedure; House legislators reportedly neglected to have their votes counted.Similar noncombat awards of the Medal of Honor were also authorized by special statutes and awarded to naval aviators [[Richard E. Byrd]] and [[Floyd Bennett]], as well as arctic explorer [[Adolphus W. Greely]].In addition, the Medal of Honor awarded to General [[Douglas MacArthur]] was reportedly based on the Lindbergh precedent, although MacArthur notably lacked implementing legislation, which probably rendered his award unlawful.