Abuse of power, in the form of 'malfeasance in office' or 'official misconduct,' is the commission of an unlawful act, done in an official capacity, which affects the performance of official duties. Malfeasance in office is often grounds for a for cause removal of an elected official by statute or recall election. Abuse of power can also mean a person using the power they have for their own personal gain. Abuse of power, in the form of 'malfeasance in office' or 'official misconduct,' is the commission of an unlawful act, done in an official capacity, which affects the performance of official duties. Malfeasance in office is often grounds for a for cause removal of an elected official by statute or recall election. Abuse of power can also mean a person using the power they have for their own personal gain. Institutional abuse is the maltreatment of someone (often children or older adults) by a system of power. This can range from acts similar to home-based child abuse, such as neglect, physical and sexual abuse, to the effects of assistance programs working below acceptable service standards, or relying on harsh or unfair ways to modify behavior. In February 2010, Judge John Leonardo found that Arpaio 'misused the power of his office to target members of the Board of Supervisors for criminal investigation'. In 2008, a federal grand jury began an inquiry of Arpaio for abuse of power, in connection with an FBI investigation. On August 31, 2012, the Arizona US Attorney's office announced that it was 'closing its investigation into allegations of criminal conduct' by Arpaio, without filing charges. Arpaio was investigated for politically motivated and 'bogus' prosecutions, which a former US Attorney called 'utterly unacceptable'. Phoenix Mayor Phil Gordon has called Arpaio's 'long list' of questionable prosecutions 'a reign of terror'. Fa Zheng, a Chinese man, was appointed as the Administrator (太守) of Shu commandery (蜀郡) and 'General Who Spreads Martial Might' (揚武將軍) by Liu Bei. He oversaw administrative affairs in the vicinity of Yi Province's capital Chengdu and served as Liu Bei's chief adviser. During this period of time, he abused his power by taking personal revenge against those who offended him before and killing them without reason. Some officials approached Zhuge Liang, another of Liu Bei's key advisers, and urged him to report Fa Zheng's lawless behaviour to their lord and take action against him. However, Zhuge Liang replied, 'When our lord was in Gong'an (公安), he was wary of Cao Cao's influence in the north and fearful of Sun Quan's presence in the east. Even in home territory he was afraid that Lady Sun might stir up trouble. He was in such a difficult situation at the time that he could neither advance nor retreat. Fa Xiaozhi supported and helped him so much, such that he is now able to fly high and no longer remain under others' influence. How can we stop Fa Zheng from behaving as he wishes?' Zhuge Liang was aware that Liu Bei favoured and trusted Fa Zheng, which was why he refused to intervene in this matter.