Two district attorneys complained that they were unlawfully deprived of their salary when the number of attorneys was reduced from thirteen to eleven by legislative action -- $1200 each. With the reduction in number of attorneys came the move to limit these two attorneys to service only in their counties of residence and a reduction in salary to $100 each. "When by law provision has been made for a certain number, and they have been lawfully chosen, they are protected for the term, as they would have been had the constitution itself indicated how many there should be."
Cooley, Thomas M. "James T. Fant v. the Auditor of Public Accounts (Officer Whose Term Is Fixed by the Constitution Cannot Be Removed by the Legislature)." Am. L. Reg.16 (1877): 737–48.