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During the 1950s and 1960s, landmark rulings ordering school desegregation, prison reform, and other structural changes transformed civil litigation in the United States. The most striking feature of the new model of litigation, Abram Chayes argued, was the metamorphosis of the judge into a "creator and manager of complex forms of ongoing relief, which have widespread effects on persons not before the court and require the judge's continuing involvement in administration and implementation."' In structural reform litigation cases, courts issue complex equitable remedies, and then remain seized of the matter until the remedies are implemented, with judges guiding and monitoring-at times in great detail-the creation or transformation of state bureaucracies.

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