Although Welty's departure from office on March 4, 1921, began a lull in criticism of Landis, in April, the judge made a controversial decision in the case of Francis J. Carey, a 19-year-old bank teller, who had pleaded guilty to embezzling $96,500. Carey, the sole support of his widowed mother and unmarried sisters, gained Landis's sympathy. He accused the bank of underpaying Carey, and sent the youth home with his mother. Two members of the Senate objected to Landis's actions, and the "New York Post" compared Carey with "Les Misérables's" Jean Valjean, noting "a loaf of bread [Valjean was incarcerated for stealing one and $96,500 there is a difference." A bill barring outside employment by federal judges had been introduced by Landis's foes, but had expired with the end of the congressional session in March; his opponents tried again in July, and the bill failed in the Senate on a tie vote. On September 1, 1921, the American Bar Association, a trade group of lawyers, passed a resolution of censure against Landis.