From the Introduction:
"Although the Treaty Establishing the European Community ("EC Treaty" or "Treaty") has created several procedures for combating Member States' breaches of European Community ("EC") law, the European Commission ("Commission") enforcement procedure under EC Treaty Articles 226 and 228 is still the most far-reaching and most commonly used. This Article examines the Commission's policy and strategy in enforcement proceedings under these provisions and attempts to discover the predominant European model, if such a model exists, for enforcing and supervising EC law. Although this Article will concentrate mainly on the administrative phase under Article 226, some reference will also be made to the judicial phase, when the Commission sues a Member State before the European Court of Justice (the "ECJ" or the "Court") under Article 228, since Article 226 cannot be understood without Article 228. Although much has been written on Commission enforcement, new developments and some procedural aspects merit its reassessment. Thus, this Article ultimately focuses on some general difficulties in analyzing supervision and enforcement at the European level and the problem of implementation in more general terms. …"

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