In an Ohio case, for example, an inmate furloughed to work release cost the State $1.7 million after he went to a woman's home and inflicted injuries so severe she was left almost completely paralyzed. Other case examples indicate correctional systems lost more lawsuits to inmates in 1986 and settled more than twice as many before trial than they had earlier. In 1986, reporting correctional departments paid a total of $2.7 million in compensatory damages, punitive damages, and attorney fees in cases lost to and settled with inmates. When payments to private citizens and their attorneys were included, this figure rose to $5.3 million. Of 47 responding departments, 21 lost no lawsuits; 13 departments reported making no settlements, and 9 departments neither lost nor settled any lawsuits with inmates. The Administrative Office of U.S. Courts notes a steady increase in lawsuits of about 5 to 10 percent a year. With more people in prison, it is not particularly surprising that more lawsuits are being filed. Further, legal sophistication among prisoners and inmate access to law libraries and paralegals have increased. Lawsuit surveys in several States indicate that money is not the only issue in inmate-related lawsuits; civil rights litigation resulting in mandates to correctional departments to make procedural or care changes has had far-reaching effects. The Civil Rights for Institutionalized Persons Act stipulates that a prisoner must go through a grievance system certified by the U.S. Department of Justice before he or she can file a lawsuit in court. This type of system may reduce the number of lawsuits, although all States do not yet have a certified grievance system. A tabular summary of inmate lawsuits is provided.