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Recent lawsuits asking federal courts to mandate large scale institutional change have drawn into question the traditional role of a court in litigation. This role usually terminated with a judicial decree of rights between the parties, and an order directing the parties to perform certain acts. The actual performance of those acts has customarily taken place without the participation of the court. However, in several recent cases mandating institutional change-particularly in prisons and mental hospitals-federal courts have assumed a more active role in the implementation of their orders to assure that their decrees become more than paper pronouncements. This Note focuses on one recent case in which the court became involved in the implementation of the institutional changes it had decreed. In Wyatt v. Stickney' United States District Judge Frank M. Johnson, Jr., of the Middle District of Alabama ruled that mentally impaired persons confined in Alabama state hospitals were being denied a constitutional "right to treatment,"2 and ordered a range of

The Wyatt Case: Implementation of a Judicial Decree Ordering Institutional Change