In Young v. United States ex rel. Vuitton Et Fils S. A., 481 U.S. 787 (1987), a corporation alleged another company was illegally manufacturing counterfeit goods. Id. at 790. The parties agreed to a settlement that enjoined the company from reproducing the corporation's products. Id. Later, the corporation discovered that the other company was still making counterfeit goods. Id. at 791. The enjoining court then appointed the corporation's counsel as a special prosecutor to prosecute the company for criminal contempt. Id. at 792. The United States Supreme Court reversed the conviction because the appointment of an interested party's counsel (the corporation's counsel) to conduct the contempt proceedings was improper. Id. at 814. It reasoned that "a private attorney appointed to prosecute a criminal contempt . . . certainly should be as disinterested as a public prosecutor who undertakes a prosecution." Id. at 804.