When the American Civil War began in 1861, Tyler sided with the Confederacy and won election to the Confederate House of Representatives shortly before his death. Some scholars have praised Tyler's political resolve, but historians have generally ranked his presidency lowly. The congressional ill will towards Tyler derived from the basis for his vetoes; until the presidency of the Whigs' arch-enemy Andrew Jackson, presidents rarely vetoed bills, and then only on grounds of constitutionality. Tyler's actions were in opposition to the presumed authority of Congress to make policy. Congressman John Botts, who opposed Tyler, introduced an impeachment resolution on July 10, 1842. It levied several charges against Tyler and called for a nine-member committee to investigate his behavior, with the expectation of a formal impeachment recommendation. Clay found this measure prematurely aggressive, and favored a more moderate progression toward Tyler's 'inevitable' impeachment.