Simon's appointment, as of 2015, marks the last appointment of a former member of the House of Commons as a Lord of Appeal in Ordinary (although Reginald Manningham-Buller, 1st Viscount Dilhorne, appointed before Simon but retiring after Simon, was the last serving Law Lord to have previously served in the Commons.) As noted by "The Independent" in his obituary, "Jack Simon was the last of a breed of judges who first pursued a successful career in politics before promotion to the Bench."