A 1994 comprehensive Legal Needs Study by the American Bar Association's Consortium on Legal Service and the Public found that less than 30 percent of low-income respondents who were party to legal transactions that involved a hearing or a court were "completely satisfied" with their treatment by a judge. Also, the number of formal complaints filed against State and Federal judges is increasing. For the Federal bench, complaints during a 3-year period jumped 40 percent, from 354 in 1990 to 438 in 1993. States, too, showed some marked increases during the same period. Yet, in both State and Federal systems, 90 percent or more of formal complaints against judges are ultimately dismissed, often because charges are deemed unfounded or because the disciplinary body does not have jurisdiction over complaints that essentially involve a legitimate use of judicial discretion. There are various factors, however, that make judges vulnerable to the display of arrogant, mean, and biased behavior. These include the authority of the office and the stress of heavy caseloads and interactions with attorneys. Although counseling for judges who go beyond the bounds of decorum and objectivity may prevent or remedy some problems, more open procedures for formal complaints are being adopted by some States. Revised procedures in Pennsylvania, California, and Washington State have established judicial conduct review boards that include lay membership. This trend toward more openness in the States contrasts with the closed system for Federal courts. Still, the Federal courts have established new rules that give the Judicial Council in each circuit more power to investigate problems on its own. Aggrieved parties now have a place to appeal rulings they do not like: The Committee to Review Circuit Council and Disability Orders of the Judicial Conference of the United State. This new five-member body appointed by Chief Justice William Rehnquist has thus far received two cases.