Page 40 of 42 103 Minn. L. Rev. 844, *913 not unique hybrid: it provides independent review removed from local electoral politics, yet power remains in the hands of 213, U.S. Attorneys and the U.S. Attorney General are political appointees, U.S. Const. art. II, § 2 (Appointments Clause); 28 U.S.C. § 541 (2012) ("The President shall appoint ... a United States attorney for each judicial district."), although much of the Justice Department staff are nonpolitical, civil service appointees. See Government Ethics Outline, U.S. Dep't Just., https:/Awww justice.gov/jmd/government-ethics- outline (last updated July 5, 2017) (explaining ethics rules for "non-career" political appointees and for career employees). 14 See Sanford C. Gordon, Assessing Partisan Bias in Federal Public Corruption Prosecutions, 103 Am. Pol. Sci. Rev. 534, 549 (2009) (finding evidence of political party bias among federal prosecutors). 215 The clearest historical example would be the post-Reconstruction decades, starting roughly after 1876, when the federal government retreated from civil rights enforcement in the former Confederate states, including from prosecutions for criminal rights violations and offenses that states declined to charge, including for homicides. See generally Eric Foner, Reconstruction: America's Unfinished Revolution, 1863-1877, at 524-86 (2014) (describing declining enthusiasm for civil rights enforcement and waning Republican political influence in the South); William Gillette, Retreat from Reconstruction, 1869-1879, at 190-200 (1979) (describing Southern Democrats efforts to resist civil rights enforcement); George Rutherglen, Civil Rights in the Shadow of Slavery: The Constitution, Common Law, and the Civil Rights Act of 1866, at 95-100 (2013) (describing Supreme Court decisions limiting the enforcement of the Civil Rights Act of 1866). 216 Alaska, Connecticut, and New Jersey do not elect prosecutors. Perry, supra note 122, at 2. Delaware and Rhode Island elect state attor