Anatomically the shoulder capsule (superior glenohumeral lig) unwinds in internal rotation, thus adding to subluxation in the joint. Some studies are being done using muscle stim. to the external rotators in the flaccid shoulder to see if this can help prevent subluxation during a flacid period initially post CVA. I am not aware of any literature written on it.

Often we need to question whether the subluxation causes discomfort or whether the flaccid shoulder had been damaged during manual handling of the client? This may often be the case and would support the administration of a supportive device if nothing more than to say...."Hey I have a shoulder issue....please be careful"... :-)