Early experiments in democratic participation as a component of a reeducative prison in the 19th and 20th centuries were done by Alexander Maconochie and Thomas Osborne. The just community approach at the Niantic State Prison for women in Connecticut established a prison community on a constitutional basis with participatory creation and enforcement of rules, and educational and recreational programs. A major constraint against the operation of democratic communities in prisons is the dilemma of prison administrators who are reluctant to allow inmates any degree of control over potential legal felonies or major threats to prison authority. Problems are also created by inmate elites who govern largely for their own economic and political interests. Furthermore, the position of a prison therapeutic community vis-a-vis the larger prison and correctional system within which it exists and upon which it depends for its continued existence is tenuous. Also, the achievement of social justice by prison therapeutic communities often proves elusive due to various abuses of power by inmate community officers. For example, unfair or capricious punishments are meted out to inmates; respect for individual freedom within the group is not observed; and there is no independent body to insure impartial review of decisions made by a therapeutic community. Therefore, the bureaucratization of justice in prisons serves a positive function in that social justice is removed from the hands of particular individuals. Although it is possible to balance community ideals and social justice in a prison inmate community, such a task represents a formidable accomplishment. Six references are provided.