in a California prison received a disciplinary write-up for committing suicide.85 The conditions in punitive and administrative segregation create great psychological stress and can cause symptoms of mental illness to appear even in inmates with no prior psychiatric problems. Segregated inmates are also at risk for suicide. A recent study examined nine suicides that occurred within 24 months at an unnamed large metropolitan jail; the author found that of the nine suicides, eight were segregated from the general population of the jail at the time of their death.86 The dangers of segregation have been recognized by courts in many prisoners' rights cases. For example, in 1995 a federal court held that, "Social science and clinical literature have consistently reported that when human beings are subjected to social isolation and reduced environmental stimulation, they may deteriorate mentally and in some cases develop psychiatric disturbances."87 Another federal court, presented with allegations regarding the misuse of administrative segregation in New York State prisons held that, "A conclusion ...that prolonged isolation from social and environmental stimulation increases the risk of developing mental illness does not strike this Court as rocket science."88 Too often, psychotropic medication is the only form of treatment available to prisoners with mental illness confined in punitive or administrative segregation units. Even though the Department of Correctional Services requires that a mental health counselor make daily rounds in special housing (segregation) units, actual contact with individual prisoners, in the form of conversation or counseling, is infrequent. The cumulative effect of isolation, reduced supportive services and sensory deprivation will typically leave the inmate with mental illness functioning at a lower level than before incarceration. Alienation from family and friends While incarcerated, people with mental illness ...