as well as bills of attainder. See, e.g., Nixon v. Administrator of General Services, 433 U.S. 425, 473-74, 97 S.Ct. 2777, 2805-06, 53 L.Ed.2d 867 (1977). 15 . In England, bills of pains and penalties commonly imposed imprisonment, banishment and the punitive confiscation of property. See Nixon, 433 U.S. at 474, 97 S.Ct. at 2806. In this country, the punishments forbidden by the Bill of Attainder Clause have been expanded to include statutes barring participation by individuals or groups in specific professions. See, e.g., United States v. Brown, 381 U.S. 437, 85 S.Ct. 1707, 14 L.Ed.2d 484 (1965) (law barring Communist Party members from serving as officers in labor unions held to be bill of attainder); United States v. Lovett, 328 U.S. 303, 66 S.Ct. 1073, 90 L.Ed. 1252 (1946) (<HOLDING>); Cummings v. Missouri, 71 U.S. (4 Wall.) 277,
holding that after a class is certified the controversy may exist  between a named defendant and a member of the class represented by the named plaintiff even though the claim of the named plaintiff has become moot holding that employees conviction for possession of a controlled substance constituted gross misconduct holding that law cutting off salaries to three named government employees constituted bill of attainder holding that probation department employees are not county employees holding that the use of any government resources   whether salaries employees paper or buildings  to accomplish a final listing of a species as endangered would entail government expenditure and thereby run afoul of statutory moratorium on spending for such purpose the government cannot make expenditures and therefore cannot act other than by appropriation