Rufo v. Inmates of Suffolk Cty. Jail

In Rufo v. Inmates of Suffolk Cty. Jail (1992), 502 U.S. 367, 112 S.Ct. 748, 116 L.Ed.2d 867, the United States Supreme Court addressed the standard for determining whether to modify a consent order because of changed circumstances. Pursuant to the standard set forth in Rufo: "A party seeking modification of a consent decree bears the burden of establishing that a significant change in circumstances warrants revision of the decree. If the moving party meets this standard, the court should consider whether the proposed modification is suitably tailored to the changed circumstance." Id. at 383. The Court further held that "[a] party seeking modification of a consent decree may meet its initial burden by showing a significant change either in factual conditions or law." Id. at 384. A significant change in facts warrants a modification of a decree when the change was unforseen and as a result of the change, "the decree proves to be unworkable." Id. "Once a party has met its initial burden of establishing either a change in fact or on law warranting a modification of a consent decree, the district court should determine whether the proposed modification is suitably tailored to the changed circumstance." Id. at 391.