The superintendent of the Elmira Reformatory in New York, Zebulon Brockway (1827–1920), used some of these ideas when New York opened the reformatory in 1876 for male offenders sixteen to thirty years old. Brockway believed that rehabilitation could be achieved through education.

Inmates who did well in both academic and moral subjects earned early release by accumulating points. Misbehavior and poor performance in the educational courses prolonged the individual's sentence. Brockway used this technique because the New York legislature had passed a law allowing indeterminate sentencing and the release of inmates on parole when they showed they had been reformed. Brockway recognized that it was difficult to distinguish between those inmates who had truly reformed and those who were pretending to be rehabilitated in order to be paroled.