Neither state nor federal laws adequately protect the mentally ill in Arizona. Although the Arizona Supreme Court ordered the state to establish a comprehensive mental health system in 1989, this vision has never been fully realized. When the state plays multiple roles as the lawmaker, provider, and financer of mental health services, state courts have limited power to compel the financially distressed state to live up to statutory obligations. On the federal level, the U.S. Supreme Court instructed the judiciary to defer to states’ distributive decisions with respect to their resources, thus permitting states to commit minimally to the mentally ill. Because litigation under the current legal framework is not an effective vehicle to advance the interests of the mentally ill, an alternative solution is to integrate Arizona’s carve-out mental health services into the primary care system. An integrated mental health system has the potential to improve patients’ overall well-being and reduce the long-term social and medical costs associated with inadequate mental health services.