In Phillips v. Washington Legal Found., 524 U.S. 156, 118 S. Ct. 1925, 141 L. Ed. 2d 174 (1998) the Supreme Court evaluated the constitutionality of two states' use of interest earned on the property of private individuals being held in attorneys' trust accounts ("IOLTA" accounts) to fund legal services for low income individuals. In Phillips, the Supreme Court acknowledged "the general rule that 'any interest . . . follows the principal.'" Phillips, 524 U.S. at 166, 141 L. Ed. 2d at 185. The Court then held that "interest income generated by funds held in IOLTA accounts is the 'private property' of the owner of the principal." Id. at 172, 141 L. Ed. 2d at 188. However, the Court expressed "no view as to whether these funds have been 'taken' by the State." Id.