A review of the Alabama litigation shows the progression of steps that should precede a release order and the legal problems inherent in such a remedy. Two alternative actions which can result in release are examined: prisoner challenges under Section 1983 and challenges under habeas corpus. This discussion concludes that Section 1983 actions offer the most flexibility for both courts and litigants, although limitations on its use for ordering prisoner releases exist. Other areas covered include the erosion of traditional barriers to prisoners' litigation, lawsuits challenging prison conditions under Section 1983, and ramifications of release as a remedy. The paper concludes that, although the device of releasing prisoners to remedy constitutional violations should not be employed casually, it should not be eliminated from the spectrum of remedies available to the courts. 216 footnotes.