In the Holt case, the judge relied on traditional remedies and procedures from the law of equity. Thus, the defendants prepared a proposed decree which was used as the basis for the eventual order. The judge also relied on plaintiffs' attorneys and the plaintiffs themselves through the device of inmate complaints in monitoring compliance with the decree. In the Pugh case, Judge Frank M. Johnson, Jr. held institutions in Alabama to be unconstitutional. The judge formulated the decree himself, appointed a citizen's committee to monitor compliance, and eventually appointed a receiver for the Alabama prison system. The Pugh decree was specific, whereas the Hold decree was general in nature. Nevertheless, the two cases have several decision points in common. Moreover, the prison systems in both Alabama and Arkansas are still under court order. In the case of Alberti v. Sheriff of Harris County, Tex. the judge's decision path was more like that in the Pugh case than that in the Holt case, but the judge was more successful in achieving reform than was Judge Johnson. The judge's determination and the willingness to comply by one or more necessary actors probably accounted for this result. A recent Harvard Law Review article recommends procedures that reflect the reality that the decision path may not be as important as avoiding the early elimination of options that the judge may need to use later. These procedures represent a more effective model than any yet used in that they are flexible and avoid either heavy or minimal reliance on the plaintiffs. Reference notes are provided.