When I am creating and snow or iron golem you can create it with snow or iron in any direction. See photo for example. In pic I didn't place pumpkin last but if you try it placing pumpkin last it will spawn.
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This is how it is supposed to work.
See: http://minecraft.gamepedia.com/Snow_Golem
...the snow golem can be built upright, lying down, or even upside-down.
And: http://minecraft.gamepedia.com/Iron_Golem
The block arrangement can be placed upright, lying down, or upside-down.
Sorry, I'm on a Samsung Galaxy Tab E