I think both the Civil Rights Act and the women’s movement did in fact lead to tremendous net increases in liberty... Federal intervention, while certainly limiting freedom of association and trumping more local jurisdictions, resulted IMO in an overall increase in freedom. That many traditional libertarian conservatives, such as Goldwater, seem to have been willing to sacrifice a great gain in overall freedom in order to maintain status quo levels local self-rule seems to me to betray a commitment to ancient ideals of liberty as community self-government in conflict with the modern idea of liberty as freedom from coercion.
--Wilkinson on Bartlett on liberals and libertarians.
My hypothesis is that conservatives (and right-leaning libertarians) tend to invoke "federal intervention" and "judicial activism" when talking about the means to ends that they don't personally care for and/or to which they are indifferent. If, for example, Kelo had been decided differently (i.e., correctly), would conservatives have been howling federal overreach in the governance of New London? I somewhat doubt it.