See McConnell & Picker, 60 U. Chi. L.Rev. at 427-29, 450-54 (summarizing the history). Although it had a rocky start, see, e.g., Ashton, 298 U.S. at 530-32, 56 S.Ct. 892 (invalidating the initial act), Congress eventually succeeded in avoiding a Tenth Amendment problem. It did so in part by requiring a state’s consent in the federal municipal bankruptcy regime before permitting municipalities of that state to seek relief under it, and in part by emphasizing that the statute did not effect “ ‘any restriction on the powers of the States or their arms of government in the exercise of their sovereign rights and duties.’ ” See, e.g., United States v. Bekins, 304 U.S. 27, 49-54, 58 S.Ct. 811, 82 L.Ed. 1137 (1938) (quoting H.R.Rep. No. 75-517, at 2 (1937); S.Rep. No. 75911, at 2 (1937)) (<HOLDING>); cf. McConnell & Picker, 60 U. Chi. L.Rev. at
recognizing that this created a cooperative scheme recognizing this presumption recognizing that prior decisions created confusion on this point recognizing that the regulatory scheme created by the ina is so pervasive as to be consistent with the exclusive federal power over immigration recognizing this rule