The case of Robert C. Rufo, Sheriff of Suffolk County, et al. v. Inmates of the Suffolk County Jail, et al., 1991 revolved around a consent decree that had been previously agreed upon to improve conditions at the jail in question. The sheriff sought to modify this agreement due to changes in circumstances and financial constraints which made compliance difficult; however, inmates argued against this modification as they believed it would lead to a deterioration in their living conditions. The Supreme Court ruled that federal courts have the authority under Rule 60(b)(5) of Federal Rules for Civil Procedure to modify such decrees if there are significant changes in factual or legal circumstances since its establishment - provided these modifications do not undermine basic rights protected by law or constitutionally guaranteed liberties.

In the dissenting opinion for Rufo v. Inmates of Suffolk County Jail, Justice Scalia argued that the majority's decision to allow modification of a consent decree based on "significant changes in factual conditions" was too broad and could lead to abuse. He contended that such modifications should only be allowed if they are necessary to remedy violations of federal law, which is not applicable in this case as there were no allegations or findings of any new legal violations by the jail officials. Furthermore, he criticized the majority's reliance on Rule 60(b) from Federal Rules of Civil Procedure as it pertains primarily to private litigation and does not apply well in institutional reform litigation like this one where public authorities are involved. He also expressed concern about potential negative impacts on separation-of-powers principles due to judicial overreach into executive functions.