The United States has maintained unilateral sanctions against Muammar Qadhafi's Libya for almost 20 years. It has attempted to isolate Libya politically, economically, diplomatically, and militarily since 1981 in an effort to reverse that country's support for international terrorism, regional subversion, and pursuit of weapons of mass destruction. Similar to U.S. practice with other 'rogue' states, such a policy of isolation has little to show in the way of positive results 20 years later. This paper will use U.S. policy toward Libya as a case study in judging the utility and practicality of using a 'rogue' state construct, and containment as the policy of choice toward such a state. The paper will argue that the case of Libya shows that a policy of conditional engagement has far greater potential for altering that state's behavior than the present course of unilateral containment.