Although the history of penal reform in the United States over the last decade has been a history of judicial action, this judicial action has not made American prisons humane according to the standards of the Helsinki accords. There is much that the courts still refuse to correct, such as lack of inmate programs, inadequate and inhumane visitation, failure to meet health standards regarding living space, and lack of access to the public. There is much that appears impervious to reform; five years after a landmark ruling in Alabama, the court found it necessary to release inmates, because the State had failed to comply with its overcrowding orders. Attitudes are difficult to change, and the lack of resources and the overincarceration that result in the violent, crowded, and physically inadequate facilities documented in this discussion are still characteristic of corrections in the United States. A total of 229 footnotes are provided. (Author summary modified)