After the Reference, all provinces had salary commissions. The Reference also inspired the federal government under Prime Minister Jean Chrétien to establish a salary commission for federal judges, the Judicial Compensation and Benefits Commission. Still, the "Provincial Judges Reference" sparked further litigation as some provincial government's decisions not to follow commissions' salary recommendations were challenged in the courts. The Supreme Court addressed the matter again in 2005 in "Provincial Court Judges' Assn. of New Brunswick v. New Brunswick (Minister of Justice)" and urged courts to be deferential when governments give sufficient reasons for rejecting salary commissions' recommendations.