In City and County of San Francisco v. Cobra Solutions, Inc. (2006) 38 Cal.4th 839, an attorney who had formerly represented a client in government contract negotiations with a city was ultimately elected city attorney. When the city then brought a civil action against the city attorney's former client, for fraud and breach of contract, the former client sought to recuse the entire city attorney's office. The Supreme Court noted that, as the case before it was a civil matter, the restrictions imposed by Penal Code section 1424 did not apply. (Cobra Solutions, supra, 38 Cal.4th at p. 850.) Instead, the Supreme Court recognized that the source of a trial court's power to recuse a city attorney in a civil case is the trial court's inherent power to control the conduct of its ministerial officers and all others connected with a judicial proceeding before it. (38 Cal.4th at p. 846.) At issue in Cobra Solutions was whether the judicially created rule of vicarious disqualification of an entire law firm in a civil matter should apply to a government law office when the head of that office has a conflict due to a former representation of a client the office is presently pursuing. (Cobra Solutions, supra, 38 Cal.4th at p. 848.) In considering whether to apply the rule of vicarious disqualification to a government law office in a civil matter, the Supreme Court considered the policy issues which, in Greer and Younger, had supported a rule allowing disqualification of a prosecutor for an appearance of impropriety only. The Supreme Court concluded that those policy concerns remained valid, and would justify vicarious disqualification of the entire city attorney's office in the case before it. (Cobra Solutions, supra, 38 Cal.4th at pp. 850-851, 854.) However, the Supreme Court was careful to acknowledge that the standard of Greer and Younger no longer applied in criminal cases, due to the enactment of Penal Code section 1424. The court stated: "The disqualification standard that the Court of Appeal applied in Younger v. Superior Court (1978) 77 Cal.App.3d 892 no longer controls criminal prosecutions because the Legislature in 1980 enacted Penal Code section 1424 , which provides for the recusal of local prosecuting agencies only when 'the evidence shows that a conflict of interest exists that would render it unlikely that the defendant would receive a fair trial.' Section 1424 is inapplicable to this case, which is a civil action. Although the statute, which triggers disqualification of a prosecutor from a criminal proceeding 'only if' the conflict is ' "so grave as to render it unlikely that the defendant will receive fair treatment" ' , has superseded Younger's holding , the concerns that the Court of Appeal in Younger expressed about conflicted heads of public law offices, whose policymaking and supervisory duties are such as to preclude them from being effectively screened, have not lost their relevance." (Cobra Solutions, supra, 38 Cal.4th at p. 850.)