He is the second person (after SGM Frederick William Gerber) to be awarded the Medal of Honor for "lifetime achievement" rather than for acts of physical courage at the risk of one's own life. Greely's medal was awarded in contradiction to the revised 1916 Army warrant requiring combat action and risk of life "above and beyond the call of duty." However, his medal was the second, and last, Army presentation contrary to the combat requirement, as Charles Lindbergh (an Army reservist not on active duty) received the award for his solo transatlantic flight eight years before, in 1927. Until after WWII the Navy Medal of Honor could be awarded for noncombat actions, reflecting different criteria within the United States armed forces.