Horowitz' study of four cases of judicial policymaking concludes that it has severe limitations due to (1) actions being limited to the issues before the court, thus preventing a comprehensive policy approach; (2) limited opportunity for policy review; (3) judicial indifference to cost-benefit issues; and (4) a lack of structure for reasonable compromise. The Taylor v. Sterrett case, which involved the court's finding that conditions in the Dallas County Jail violated prisoners' rights under Texas statutes, did, however, result in significant change in jail conditions. Reasons for success in this case were due largely to the prisoners' lawyers not pursuing the case in a one-issue-at-a-time fashion; rather, they alleged massive violations of rights whose correction fostered comprehensive judicial policymaking. Further, the judge appointed a special master (corrections expert) to evaluate jail conditions and make recommendations. The judge maintained continuing review over compliance efforts and regularly required detailed progress reports. The court was also flexible in setting a timetable for compliance. This case contrasted with the cases examined by Horowitz in the clarity of issues presented to the court and the court's specification of precise quantifiable actions. Twenty-six references are listed.