The influence of muscle activity and forearm position on the stability of the lateral collateral ligament deficient elbow was investigated in vitro, using a custom testing apparatus to simulate active and passive elbow flexion. Rotation of the ulna relative to the humerus was measured before and after sectioning of the joint capsule, and the radial and lateral ulnar collateral ligaments from the lateral epicondyle. Gross instability was present after lateral collateral ligament transection during passive elbow flexion with the arm in the varus orientation. In the vertical orientation during passive elbow flexion, stability of the lateral collateral ligament deficient elbow was similar to the intact elbow with the forearm held in pronation, but not similar to the intact elbow when maintained in supination. This instability with the forearm supinated was reduced significantly when simulated active flexion was done. The stabilizing effect of muscle activity suggests physical therapy of the lateral collateral ligament deficient elbow should focus on active rather than passive mobilization, while avoiding shoulder abduction to minimize varus elbow stress. Passive mobilization should be done with the forearm maintained in pronation.