forced private practitioners to reject certain types of cases, such as medical malpractice, sexual abuse, and especially civil rights. 8 Finally, Philip R. Lochner, Jr., found that lawyers he studied who engaged in pro bono work initiated few legal actions for their indigent clients and settled most with dispatch. 9 None of the over 150 lawyers he interviewed brought law reform cases.
Thus, private lawyers often have strong personal, professional, and financial ties to local interests. Under these circumstances, indigents may expect no more than out-of-court settlements on narrowly conceived issues and occasional appearances in lower courts. Moreover, if the Reagan administration proposals are adopted, the poor lose any opportunity they now have to upgrade their status in courts from one-shotters to repeat-players.
In conclusion, this study has focused primarily on the initial stage in the process of social reform. MCLS lawyers and the community groups they represent have been able to establish many rights for the poor as a result of law reform victories, but the impact of these victories is frequently unclear. Although they won material victories and community organizations monitored their implementation, it is often impossible to force compliance when legal victories run counter to prevailing power relationships. 10 The enforcement problem is illustrated by the fact that the Metro City Housing Authority repeatedly refused to comply with court orders to improve housing conditions, even subsequent to being held in contempt of court. Therefore, the rights created by legal victories may be most significant not for their direct impact on poverty conditions, but rather as Stuart Scheingold argues, as resources to be employed in an on- going struggle for implementation and political power. 11 Community groups may use the symbolism of rights established by courts to mobilize political support for their implementation and for their broader political goals. 12 Scheingold writes that, "litigation can politicize individual discontents and in so doing activate a constituency thus lending initial impetus to a movement for change." 13 Ultimately, this may be the most significant contribution poverty attorneys make in the struggle for social justice.