In Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367, 378, 112 S.Ct. 748, 757, 116 L.Ed.2d 867, 883 (1992), a prisoners' rights case, the sheriff sought to modify a consent decree's restriction to one prisoner in a cell to allow double-bunking, based on: (1) an unforeseen increase in the inmate population and; (2) a Supreme Court opinion delivered after the consent decree which allowed two prisoners per cell. 502 U.S. at 376, 112 S.Ct. at 756, 116 L.Ed.2d at 881. In holding that the motion should be governed by Fed.R.Civ.P. 60(b)(5), the federal equivalent of R. 4:50-1(e), the Court reasoned: There is no suggestion in these cases that a consent decree is not subject to Rule 60(b). A consent decree no doubt embodies an agreement of the parties and thus in some respects is contractual in nature. But it is an agreement that the parties desire and expect will be reflected in, and be enforceable as, a judicial decree that is subject to the rules generally applicable to other judgments and decrees. 502 U.S. at 378, 112 S.Ct. at 757, 116 L.Ed.2d at 883. Rufo holds that "a party seeking modification of a consent decree must establish that a significant change in facts or law warrants revision of the decree and that the proposed modification is suitably tailored to the changed circumstance." Id. at 502 U.S. 393, 112 S.Ct. at 765, 116 L.Ed.2d at 892. The factual changes which may warrant modification include conditions which make compliance with the decree substantially more onerous, when a decree proves to be unworkable because of unforeseen obstacles, or where enforcement without modification would be detrimental to the public interest. Id. at 502 U.S. 384, 112 S.Ct. at 760, 116 L.Ed.2d at 886-87. The factual changes need not be limited to those which were both unforeseen and unforeseeable. Id. at 502 U.S. 385, 112 S.Ct. 760, 116 L.Ed.2d at 887. "Ordinarily, however, modification should not be granted where a party relies upon events that actually were anticipated at the time it entered into a decree." Ibid. A change in law warrants modification where a statute or court decision "has changed to make legal what the decree was designed to prevent." Id. at 502 U.S. 388, 112 S.Ct. at 748, 116 L.Ed.2d at 888. However, the moving party may be held to the agreement even if it requires the party to do more than what would be minimally required by the change in law. Id. at 502 U.S. 389, 112 S.Ct. at 762, 116 L.Ed.2d at 889. A mere clarification in the law does not in itself justify relief; to hold otherwise "would undermine the finality of such agreements and could serve as a disincentive to negotiation of settlements in institutional reform litigation." Id. at 502 U.S. 390-91, 112 S.Ct. at 764, 116 L.Ed.2d at 890. Finally, "once a moving party has met its burden of establishing either a change in fact or in law warranting modification of a consent decree, the district court should determine whether the proposed modification is suitably tailored to the changed circumstance." Id. at 502 U.S. 393, 112 S.Ct. at 765, 116 L.Ed.2d at 892. "A proposed modification should not strive to rewrite a consent decree so that it conforms to the constitutional floor." Id. at 502 U.S. 391, 112 S.Ct. at 764, 116 L.Ed.2d at 891.