This paper evaluates the various descriptions theorists and commentators have offered about how institutional reform litigation operates, in light of the Scott County Jail case of Gray v. Ferrell--No. S81-0018C (E.D. Mo.). What makes Gray a useful case for such evaluation is that, while in many ways the case is quite typical of prison litigation, in other ways it is quite different from the prison litigation scholars have written about. The obvious distinction is that the litigation involved a very small jail. Additionally, the operation of the Gray litigation contradicts a theory to which many institutional reform litigation scholars subscribe. Contrary to the majority of prison cases resulting in significant social reform, Gray appears to have led to real and lasting reform notwithstanding the complete disappearance of plaintiffs’ counsel after he won what could very well have turned out to be merely a paper victory. The author concludes that the usual paradigm for successful institutional reform litigation does not necessarily hold true for small county jails. Neither of the two descriptive camps, unilateralist and multilateralist, has recognized that the dynamics of institutional reform litigation are different in small county jails. As Gray suggests, once litigation concludes and a settlement is reached, enforcement is not necessarily driven by the adversarial process; rather, it is effectuated by a single post-order stakeholder when the benefits of successful implementation inure to the defendants themselves, the jailers.