Although law enforcement and corrections officials in both the criminal and juvenile justice systems contend that pepperspray is effective, relatively harmless, and safer than other methods of subduing unruly inmates, the spray poses risks for a variety of long-term injuries, particularly for asthmatics, and has great potential for abuse, even with stringent safeguards. Washington's Juvenile Rehabilitation Administration has approved the use of pepperspray, but three of the agency's four juvenile institutions make little or no use of the spray. However, staff at the Green Hill School, a 200-bed facility for older and more serious offenders, have used it at least 125 times since it was authorized in October 1990. The lawsuit, Horton, et al. v. Williams, et al., was filed in August 1994. The case challenges policies on the use of pepperspray and also raises claims concerning basic and special education, medical and health services, treatment programs, and the condition of the physical plant. Videotapes of pepperspray use suggest that punishment rather than institutional security was the main purpose of using the spray. Defendants contended that the use of the spray was justified because youths who failed to follow orders presented a threat to institutional security and that pepperspray is preferable to physical force because it reduces the risk of serious injury to both youth and staff. The judge has considered the spray a weapon and enjoined its use except in situations reasonably likely to result in injury to persons or a substantial amount of property. The trial is scheduled for November 1995. Photographs