Lame duck mess ups

In class we are learning about Marbury Vs. Madison. Marbury Vs. Madison was a very famous case between Thomas Jefferson and John Adams. Thomas Jefferson defeated John Adams in the case between the "Midnight Judjes" where John Adams, in his lame duck period, appointed new judges to continue his views in the office as he was being taken over. In fact this is a very old case, but yet this is still happening today. Presidents usually enter their lame duck period when they know that they are going to leave office. In this matter, the two conflicting presidents did not share views; in which John Adams appointed numerous new judges in fear that this new president would not succeed as well as he did in able to fill up the slots (as to when the president does come back to office, they can't pick their replacements under their views. This might not always be "judges" per say, but they might release people from prison with pardons. Usually they try reap the benefits of their ridiculous government salary at the end because he is not coming back to office ever again. So why 1803 they banned such a thing, but in 1900's they still have stuff like this still happening.