Through judicial review, supra-national and municipal courts are increasingly involved in determining the parameters of European states’ public policies. Yet, how and why judicial decisions impact policy change is under theorised. Existing political science approaches tend to emphasise structural and ideational factors influencing when and why policy change happens. These do not account for qualitative variation in policy change where governments openly oppose, yet implement compliant reforms. Combining critical framing analysis of governmental discourse (Verloo) with a differentiation of the generality of governing ideas impacted by policy change (Schmidt), this paper presents an approach to explaining variations in ‘reluctant’ policy change according to how it is framed and justified in government documents and rhetoric. Illustrative examples are drawn from comparative research on reforms to UK immigration policies. Attention is also given to the potential to apply this methodology to other ‘hard cases’ of reluctant policy change.
