Shakman v. Pritzker

Dist. Ct. erred in denying defendant-Governor’s motion under Rule 60(b)(5) to vacate Shakman Decree that had been entered in 1972 to preclude Governor and units of local government from conditioning employment decisions on political patronage. Defendant was able to show that 1972 judgment has been satisfied, where: (1) last significant violation of decree occurred nearly 10 years ago with patronage scandal within Dept. of Transportation, and there was no finding of patronage practices harming individual employees or applicants within last seven years; and (2) Governor’s office has instituted or supported several remedial measures in recent years to minimize risk of political patronage in employment practices. Fact that Dist. Ct. believed defendant could do more to implement Governor’s Employment Plan or that there was still risk of unlawful political patronage did not require different result. Ct. of Appeals also observed that continuing to hold defendant to 1972 consent decree would affront principles of federalism and improperly leave Dist. Ct. with playing role at odds with Case or Controversy limitation in Article III of U.S. Constitution. Dist. Ct., though, is available to consider individual claims alleging unlawful patronage.