The Use of the Phrase "Police Action" Was First Used

The use of the phrase "police action" was first used to justify the use of the U.S. military abroad without congressional approval by

A) Thomas Jefferson in his war against the Barbary Pirates.
B) Abraham Lincoln in the Civil War.
C) Harry Truman in the Korean War.
D) Lyndon Johnson in the Vietnam War.
E) George H.W. Bush in the First Gulf War.