"Pardongate" was the Bill Clinton pardon controversy when critics attacked his manner of giving out 450 pardons, a third of them on his last day in office. Scholars use two different models to describe the pardons process. Clinton used the presidential model, viewing the pardon power as a convenient resource to be used to help party activists or to advance specific policy goals. Critics favored the agency model, which views the pardons process as a nonpolitical matter for legal experts in the Department of Justice. An investigation found that he was legally within his rights.