Although gang activity, drug culture, informers, rules relaxation, the increasing rate of inmate damage suits (and the likihood that prison officials may be held personally liable for inmates' injuries) have forced a trend toward protective custody units to safeguard certain inmates, the problems of overflow and unconstitutional restriction in these units have generated new litigation. Inmates assigned to these units are beginning to challenge the conditions of their confinement. For many inmates, the physical deprivation of protective custody is exacerbated by the sense that they are the objects of community contempt and by the fear of retaliation once they are released. Some prison psychiatric services personnel ocntend that depression, schizophrenia, and suicidal behavior may all be triggered by protective custody. Yet a 1979 Supreme Court decision upheld the idea that the courts should not interfere in matters of prison administration unless it can be shown that prison officials are making an 'exaggerated response' to security problems. Legal observers believe that the decision will continue to limit the relief the courts grant to protective custody inmates in the future. Whether or not they face lawsuits, prison administrators in several States are looking for ways of dealing with the boredom, fear, and overcrowding of protective custody units. For example, California has devoted an entire facility to protective custody which allows inmates their full rights to education, prison industries, and exercise. In addition, prisons at Shelton, Wash., and Stillwater, Minn., are experimenting with ways to enrich the lives of protective custody inmates within the confines of a regular prison. Other prisons attempt to prepare protective custody inmates to return to the regular prison cellblock routine.