The Federal complaint, Dunn v. Voinovich, alleged that the mental health delivery system in Ohio's prisons was deliberately indifferent and thus violated the Constitution's Eighth Amendment. Soon after the Dunn complaint was filed the attorneys for the various parties agreed to place the lawsuit on the inactive trial docket and to retain a group of independent experts to study and report to them on Ohio prisons' mental health delivery system. The team studied the historical record, toured prisons, interviewed employees and others, and reviewed documents and records. The expert team concluded that the defendants were seriously deficient in appropriate personnel, treatment/bed space, and access to care. Deficiencies included inadequate intake screening, overuse of lockdown for inmates with mental illness, lack of relevant training, deficient records, and absence of treatment protocols or guidelines. Ohio officials began to take positive steps even before the report was issued. A three-page, highly specific consent decree was signed on July 10, 1995. It set the stage for a massive overhaul of Ohio's correctional mental health delivery model, a commitment of significant resources, and the provision of oversight. Reference notes