Also known as special prosecutor. An independent counsel is appointed on the recommendation of the Attorney General to investigate possible wrongdoing by senior officials in the executive branch, including the president. The appointment itself is made by a panel of three federal appellate court judges. A special prosecutor is considered necessary to avoid a conflict of interest that might otherwise occur if the case was investigated by Justice Department prosecutors. The current independent counsel statute was created as part of the Ethics in Government Act of 1978, following the Watergate scandal in 1974. In 1998, in the wake of independent counsel Kenneth Starr's four-year investigation of President Clinton, the statute has been criticized for allowing prosecutors too much power. The independent counsel law expired in 1999, and was replaced by the U.S. Department of Justice Office of Special Counsel.