On December 23, 2008, US President George W. Bush issued 19 presidential pardons. Presidential pardons are granted under Article II, section 2 of the US Constitution and are reviewed by the US Department of Justice Office of the Pardon Attorney. Most notably, Bush granted the second posthumous, presidential pardon in history to Charles Thompson Winters who was convicted in 1948 of exporting military aircraft to Israel in violation of the Neutrality Act of 1939. Although many sought pardons from Bush at the end of his eight-year term, he only issued a total of 200 pardons during his presidency. Bush issued the second least number of pardons by any President since the start of the twentieth century behind his father George H.W. Bush, who issued 77.