There are two major difficulties in viewing the jury as a policymaker. First, the jury does not deliberately make policy. Second, the decision of a jury is directed toward a unique set of circumstances concerning activities occurring in the past. Nevertheless, two principal forms of jury policymaking are clearly discernible. The nullification process, the power of jurors to ignore instructions of the court and reach verdicts based upon their own consciences and interpretations of the law, is the first such form. In addition, the jury makes policy in the guise of 'fact-finding,' as in a negligence case, where the jury must determine whether a defendant acted reasonably. Several analytical perspectives can be employed to advance an understanding of the role of the jury in the policymaking process. It is argued that legal history reform may be viewed as a gradual modification of a complex structure, rather than an abrupt, clearly defined change. In such a context, the jury may be seen as an evaluator of the gradual changes of policy under the concept of incrementalism. The second approach, the systems approach, views the jury as part of the judicial system or as a system unto itself, which interacts with other aspects of the political system. For example, outputs of the legislative and executive systems may serve as inputs for the judicial system. The decentralization perspective emphasizes the use of discretionary power by individuals claiming no particular expertise with regard to the issues to be decided. The three approaches or perspectives may be viewed as interrelated; the decentralized structure enables juries to engender incremental changes. It is suggested that if the jury's policymaking role is to be encouraged the issue of accountability must be addressed. Footnotes are included in the article.