THE ARKANSAS PRISON CASES THAT MARK THE BEGINNING OF FEDERAL JUDICIAL INVOLVEMENT IN PRISON LITIGATION ARE REVIEWED. THESE CASES ILLUSTRATE THE GREATEST OBSTACLE TO EFFECTIVE CLASS ACTION LITIGATION REGARDING PRISONS: OBTAINING FULL COMPLIANCE WITH COURT ORDERS. THE DEVELOPMENT OF PRISONERS' RIGHTS IS TRACED THROUGH JUDICIAL DECISIONS PERTAINING TO THE KINDS OF ACTIONS PRISONERS (STATE AND FEDERAL) MAY BRING, THE RIGHT TO DECENT CONDITIONS OF CONFINEMENT, THE RIGHT TO MEDICAL CARE, THE RIGHT TO REHABILITATIVE TREATMENT, AND THE RIGHT TO REFUSE PSYCHIATRIC TREATMENT. PROBLEMS STEMMING FROM JUDICIAL ACTIVISM IN PRISON REFORM ARE DISCUSSED, INCLUDING THE MANAGEMENT OF PRISON LITIGATION CASELOADS, JUDICIAL INVOLVEMENT IN PRISON ADMINISTRATION, AND DIFFICULTIES IN SECURING COMPLIANCE WITH COURT-ORDERED RELIEF. IT IS CONCLUDED THAT, AS THE EXTENSIVE CONSTITUTIONAL RIGHTS OF PRISONERS HAVE BEEN DELINEATED WITH SOME CARE AND THE WORST ABUSES HAVE BEEN CURTAILED BY FEDERAL COURT ACTION, IT MAY BE TIME FOR PRISONERS TO TURN TO INDIVIDUAL DAMAGE LITIGATION TO SECURE THEIR RIGHTS. IT MAY ALSO BE TIME TO BEGIN ENFORCING PRISONERS' RIGHTS THROUGH STATUTES AND REGULATIONS. THE FEDERAL COURTS HAVE BEEN FORCED BY INTOLERABLE CIRCUMSTANCES TO ACT BEYOND THE CUSTOMARY BOUNDS OF THEIR JURISDICTION. THEIR ACHIEVEMENTS SHOULD BE APPLAUDED, BUT THE SEARCH FOR A BETTER MEANS OF SECURING PRISONERS' RIGHTS SHOULD CONTINUE. (LKM)