I'm afraid that using a recess appointment will ensure that the recess appointee will never be confirmed. However, I'd be willing to forego any chance of a lifetime appoinment for a one year stint on the court of appeals. Then after they've seen what I can do with a year, the Senate would gladly vote to confirm Estrada for life.
From Barbara Olson's book
Hell To Pay, page 130:
"When President Reagan set out to appoint a board [of the Legal Services Corporation] of his own through recess appointments, Hillary masterminded a lawsuit arguing that such recess appointments were illegal (though she, herself, had been appointed in just this way).