Page 13 of 42 103 Minn. L. Rev. 844, *867 once common and significant in many state justice systems. U.S. colonies and states created public prosecution offices much earlier than England. 77 [*868] Even so, in the nation's earliest decades, those officials were often part-time or short-term officials, whose duties were often primarily quasi-judicial or administrative. 7® For those reasons, in many states those officials coexisted alongside private prosecutors with whom they shared some similarities. Early public prosecutors were paid by the case or the conviction 7 and pursued cases from private complainants. °° But by the mid-nineteenth century, every state had public prosecutor offices of some sort. ®! Increasingly, they were full-time and accompanied by [*869] public police forces. In this context, private prosecutions diminished, then vanished. °? However, because public prosecutors continued to suffer from poor funding (and consequently were held in low regard), *° some states continued an alternate form of private prosecution: privately funded attorneys could assist in criminal prosecutions as long as the public prosecutor supervised or retained formal control. *4 This form of ancillary or supplementary private prosecution, which leaves charging decisions in public hands, is still permitted in several states. °° Otherwise, only vestiges of private [*870] prosecution remain in a few states. Pennsylvania seems to have the strongest version: it permits private prosecutions for any offense upon the approval from a state prosecutor or a judge. *®° Rhode Island authorizes private prosecutions only for misdemeanors. 8’ Under state common law, New Hampshire might permit the same for nonjailable offenses. °° Beyond that, judges in many states can issue an arrest warrant or criminal summons based on a private person's testimony, but public prosecutors control whether to go forward with the case. 8? [*871] In sum, U.S. jurisdictions are unusual among common law juris