Interpretive content analysis is used in judicial biographies when the texts of judicial opinions or private papers are related to earlier life experiences. Systematic content analysis requires rigorous procedures for obtaining reliable data that are intersubjectively verifiable. Controls on subjectivity such as research panels or computer-based text searches are often used. While content analysis can be a flexible research tool, it does have limitations, especially when undertaking exploratory research. Additionally, while content analysis can produce more reliable data, it does not affect the data's validity. Content analysis cannot substitute for a judge's loss of memory about the details of a decision or for the deliberate distortion of a written record. Content analysis will yield data only if the data being analyzed are valid; it will assure that data are reproducible, but cannot guarantee that they are representative. 15 footnotes.