Eleven of those jurisdictions have been ordered to improve conditions throughout their entire prison systems. In 1992, constitutional challenges to a variety of State prison conditions were initiated or pending in 13 States and D.C. The contested conditions included physical health care, mental health care, access to legal services, violence, prison conditions for women, handling of prisoners with HIV infection and tuberculosis, and HIV education. However, overcrowding remained the most frequently litigated condition. Court orders result from lawsuits brought by inmates challenging prison conditions; when the courts rule in favor of the plaintiffs, it is on grounds that their Eighth Amendment rights prohibiting cruel and unusual punishment were violated. Parties seeking to minimize litigation costs negotiate a consent decree settlement, which must be approved by the court.