In recent years, both popular I and academic 2 attention has begun to focus on the innovative and expansive remedies that federal courts have utilized with increasing frequency, especially against state governments. These forms of relief raise the question whether the judiciary has begun to tolerate in itself a blending of functions that would never be tolerated in another branch of government. 3 Federal district courts largely have assumed the duties of administering a state mental health system 4 and a state prison. 5 Many feder
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