See Commonwealth v. Gibbs, 70 Mass. (4 Gray) 146, 147-48 (1855); Meister v. People, 31 Mich. 99, 104-06 (1875); Biemel v. State, 37 N.W.244, 248-49 (Wis. 1888). See also Ireland, supra note 83, at 49 (listing fifteen states that still approved privately funded prosecutors in 1900). Other states abolished th