Lafe Solomon was named Acting General Counsel on June21, 2010. His nomination was sent to the Senate on January5, 2011. Solomon's authority came into question on August13, 2013, when Judge Benjamin Settle for the United States District Court for the Western District of Washington denied a petition for injunctive relief, ruling that Solomon had not been properly appointed under the Federal Vacancies Reform Act of 1998 (FVRA). Although other district courts had enforced Solomon's requests, Settle's decision called into question all of Solomon's activity since June21, 2010, focusing on subsections (a)(1) and (2) of the FVRA; some pundits claimed that Solomon's appointment was allowed under subsection (a)(3). President Obama withdrew Solomon's nomination.