Blair,
It's hard for me to imagine a facet stuck in a subluxated position. If it were subluxated, I would expect the pain to be more than you could tolerate and that they would be resolving the subluxation with external manipulation.... possibly even manipulation under anesthesia. If it were to remain subluxated or continue to find it's way into a subluxated position, then I would suspect that there was a substantial instability and structural issue... possibly a fracture, blown ligament, blown facet capsule, or ??? My guess is that this would ultimately result in treatment that is a step further than ADR, like posterior stabilization or fusion.
I do know people who have required stabilization after ADR. Each case is quite unique... some have done well and some have not. In the cases where the indications were clear, they have done well.
Mark
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