In "The Transformation of American Law, 1870-1960: The Crisis of Legal Orthodoxy" (1992), the sequel to his first book, Horwitz focused on the critics of the system which he described in his first book, especially Oliver Wendell Holmes, Roscoe Pound, and Karl Llewellyn. He frames this change in the law as a debate between "Legal Formalists" and "Legal Realists". He argues that in this period, the victors from his first book tried to present the current state of the law as the natural and necessary consequence of the application of the rules of reason. In their critique of Legal Formalism, the Legal Realists argued that the inductive and analogical model applied by the Legal Formalists was logically incoherent; that all law was ultimately a power relationship; and that, therefore, law was basically a form of public policy which should be decided on public policy grounds rather than by recourse to abstract categories like "reason".