As part of the proceedings in State ex rel. Millard E. Jewell, the West Virginia Supreme Court of Appeals appointed a special master to take evidence on some of the case's broader questions. The special master found that funding was inadequate to fulfill the State's responsibility for indigent criminal defense and that the appointed-counsel system does not 'consistently guarantee constitutionally required representation.' The special master has recommended that the West Virginia Supreme Court create a system that requires trial attorneys throughout the State to act as defense counsel for indigents, with some portion of their fees and expenses being a pro bono contribution. A suit by the Georgia American Civil Liberties Union challenging the constitutionality of indigent defense programs in Georgia was dismissed by the Federal district court, but the dismissal was overruled by the Eleventh Circuit Court of Appeals. The State has filed for a rehearing. In Virginia the 1985 legislature created two joint subcommittees to study the State's indigent defense services system. In 1986 the subcommittees recommended and the legislature adopted increases in fees paid to assigned counsel and the establishment of additional local public defender offices. A bill has been introduced in Georgia that permits attorneys in Georgia's voluntary IOLTA program to specify that interest from his or her eligible client trust funds shall be used 'for the purpose of funding any government operated or government sponsored indigent defense plan or program.'