Uncivil Litigation

Check out this article in Litigation News Online from the ABA Litigation Section.  The Board of Governors of the California Bar Association has decided that new rules are needed to reduce incivility in litigation.  Has litigation always been a nasty affair (assuming it is now)?  Or is the decrease in civility a new phenomenon (i.e., more evidence of the rise of the "abysmal tide")?–Counseller