ACT, 18 U.S.C. § 3626
100. For purposes of this lawsuit only and in order to settle this
matter, the City and the DPD stipulate that they have violated the
federal rights of inmates as alleged in the pleadings. The parties
further stipulate and agree that prospective relief in this Agreement
is narrowly drawn, extends no further than necessary to correct the
violations of federal rights set forth in the Complaint, is the least
intrusive means necessary to correct these violations and will not have
an adverse impact on public safety or the
operation of a criminal justice system. Accordingly, the parties agree
and represent to the Court that the Agreement complies in all respects
with the provisions of 18 U.S.C. § 3626(a), and may serve as the
factual and legal basis for a court order issued pursuant to those
provisions.
101. The issue of liability has not been litigated. The parties ask the
Court to approve this Agreement without a full hearing on the merits,
on the basis of the DOJ’s Complaint and the above stipulation.
102. This Agreement is not intended to have any preclusive effect
except between the parties. Should the issue of the preclusive effect
of this Agreement be raised in any proceedings other than this civil
action, the parties agree to certify that this Agreement was intended
to have no such preclusive effect.