As Associate Justices left the court in subsequent years, Washington appointed Thomas Johnson, William Paterson, and Samuel Chase. Jay stepped down as Chief Justice in 1795 and was replaced by Rutledge, who received a recess appointment as Chief Justice. Rutledge served for six months but resigned after his nomination was rejected by the Senate in December 1795; Rutledge had alienated several Senators with his criticism of the Jay Treaty. After the rejection of Rutledge's nomination, Washington appointed Oliver Ellsworth as the third Chief Justice of the United States.