Can Rule 71 be used as a basis for a contempt proceeding to enforce a consent decree?

MultiRegion, United States of America

The following excerpt is from Berger v. Heckler, 771 F.2d 1556 (2nd Cir. 1985):

In Lasky v. Quinlan, supra, a case in which no class was certified, a contempt proceeding to enforce a consent decree providing for improvements in the county jail was instituted by the original plaintiffs who were no longer in custody in that jail. The court found the action moot as to the original plaintiffs, and rejected the contention that Rule 71 provided a basis on which the original plaintiffs could enforce the decree. The court said,

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