Recent U.S. Supreme Court decisions, however, have held that Federal statutes which are primarily concerned with funding and which do not expressly authorize a private cause of action by an aggrieved party for deprivation caused by a violation of the statute may be construed implicitly to provide such a remedy. An analysis of the jail removal clause indicates that it meets the six criteria put forth by the Court for determination of the existence of an implied cause of action. The jail removal provision was enacted for the benefit of a special class (i.e., juveniles subject to incarceration). There is no indication of any congressional intent to deny a private cause of action, and the implication of a private remedy would be consistent with the stated purpose of the JJDP. The area of juvenile justice is a basic concern of both State and Federal governments. There is no evidence in the JJDP that termination of funding was intended to be an exclusive remedy. Finally, the legislative history of the act and the language of the jail removal provision are indicative of a congressional intent to establish an enforceable right. 58 footnotes.