 He voiced his opposition in 1921 to the Smith–Towner Bill, which was an unsuccessful attempt to create the U.S. Department of Education, because he believed it was both unconstitutional and unwise for the federal government to assert control over education.In the summer of 1923, Creeden developed phlebitis, which severely impacted his ability to discharge the office.By early 1924, he felt that he was no longer able to fulfill his duties, and Charles W. Lyons was named as his successor in late October 1924.