A new law review article relevant to the attack on consent decrees is available. The closing thought: In particular, to some extent, progressive scholars and policymakers have thought it relatively low-cost to allow conservatives to attack injunctive litigation. After all, if something is already dead, why expend any political capital defending it? This is a point that has a good deal of relevance right now, as Congress considers the "Federal Consent Decree Fairness Act" proposed to implement restrictions similar to the PLRA's in other topical areas of governmental injunctive litigation. If this article is correct about prison and jail orders, the stakes of the proposed "reform" are probably extremely high; progressives should think long and hard before they allow this statute or others like it to pass without a strenuous fight. --Margo Schlanger, "Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders," N.Y.U. L. Rev. (forthcoming 2006).