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February 4, 2022

Federal prison population creeping up again after initial application of FIRST STEP earned-time credits

As noted in this prior post, the Department of Justice last month announced its rules for implementing "the Time Credits program required by the First Step Act."  DOJ provided for retroactive application of these credits, which produced a notable decline in the overall federal prison population.  Specifically, as indicated in this post, over the last two full weeks of January, the federal inmate population dropped nearly 3% down to 153,293 "Total Federal Inmates" on January 27 from a count of 157,596 on January 13.  

But on February 3, 2022, the federal Bureau of Prisons updated here its report of "Total Federal Inmates," and that number now reads at 153,316.  In other words, after the initial implementation of FIRST STEP earned-time credits dropped the federal prison population, this population total now is starting to creeping up again slightly.  And because the federal prison population was steadily creeping up throughout most of 2021 — an increase of nearly 6000 from a low of 151,646 inmates as of January 21, 2021 — I will be continuing to keep a close watch on where the federal prison population might be headed the rest of this year.  

Prior recent related posts:

February 4, 2022 in FIRST STEP Act and its implementation, Prisons and prisoners | Permalink | Comments (0)

February 3, 2022

Another congressional hearing on federal prisons, this time with testimony from out-going BOP director

As noted in this prior post, a couple weeks ago the Subcommittee on Crime, Terrorism, and Homeland Security of the US House Judiciary Committee held a hearing with multiple witnesses on "The First Step Act, The Pandemic, and Compassionate Release: What Are the Next Steps for the Federal Bureau of Prisons?".  This morning, as detailed here, another similar hearing was conducted, though with only one witness, Michael Carvajal, the Director of the Federal Bureau of Prisons.  Carvajal has already resigned, though is serving until his replacement in place.  And in that role, he submitted this written testimony which is worth a full read.  Here are some excerpts:

We have begun awarding inmates FSA earned time credits for successful participation in FSA programs and moving eligible inmates to supervised release or pre-release custody. These credits are governed by a new regulation that the Bureau issued in January 2022. Working closely with other Department of Justice components, we are exercising our discretion to apply time credits towards supervised release for the sentences of over 4,900 inmates and anticipate moving over 2,500 inmates to Home Confinement or a Residential Reentry Center based on the published final rule governing the awarding of FSA earned time credits....

Based on the March 26, 2020 and April 3, 2020 guidance issued by Attorney General Barr, the Bureau began and continues to migrate eligible inmates to Home Confinement. I am pleased to report that since March 26, 2020, the Bureau has transferred more than 37,000 inmates to community custody, with more than 9,000 transferred directly pursuant to the authority granted by the CARES Act. Review of medically vulnerable inmates for potential placement in home confinement remains ongoing and will continue for the duration of the pandemic....

As the Committee is aware, the Department’s Office of Legal Counsel recently issued an opinion indicating that the Bureau may use its preexisting authorities and discretion to permit prisoners granted CARES Act Home Confinement to continue such placements after declaration of the end of the COVID-19 Emergency. The Department of Justice is preparing regulations to implement this decision....

[T]he First Step Act of 2018 paved the way for an inmate to file directly with the sentencing court, after the inmate has fully exhausted the internal appeals process, or 30 days after the warden received the inmate’s compassionate release request. Since the enactment of the FSA, we are aware of 4,025 compassionate releases regardless of the tens of thousands which have been sought. Since the passage of the CARES Act, 3,851 inmates have been released via compassionate release. The Bureau cannot track inmate-filed motions, as the Bureau is not a party to those cases....

The Elderly Offender Home Detention Program was reauthorized by the FSA, and it allows certain elderly federal inmates to seek placement on home confinement before the expiration of their prison sentence. Since passage of the FSA, the Bureau has approved 1,177 inmates to home confinement under this program.

February 3, 2022 in FIRST STEP Act and its implementation, Prisons and prisoners, Who Sentences | Permalink | Comments (0)

February 2, 2022

Rounding up some good midweek reads

A busy week amid weather warnings means not enough blog time and too much to read.  So, making up for lost time, here is a round-up of some of what I have been reading:

From the ABA Journal, "Inmate's life sentence spurs him to push for felony murder reform"

From The American Prospect, "Michelle Childs’s Punitive Criminal Justice Rulings Were Repeatedly Overturned"

From The Atlantic, "The Other Speed Trap: America’s traffic laws hurt the poor, and don’t really deter anyone. But what if traffic fines scaled with income?"

From CNN, "We need to understand America's spike in murders"

From MarketWatch, "Tough-on-crime laws and mass incarceration waste tax dollars and don’t make us any safer"

From Slate, "9-Year-Olds Are Being Forced to Register as Sex Offenders. That Might Finally Change."

From Stat, "Despite Biden’s big promises and a far better understanding of the virus, Covid-19 is still raging through the nation’s prisons"

From The Washington Post, "Biden’s Supreme Court nominee should be a criminal defense lawyer"

February 2, 2022 in Recommended reading | Permalink | Comments (8)

"Gender Favoritism Among Criminal Prosecutors"

The title of this post is the title of this new article authored by Stephanie Holmes Didwania available via SSRN. Here is its abstract:

Prosecutors enjoy wide discretion in the decisions they make but are largely unstudied by quantitative empirical scholars. This paper explores gender bias in prosecutorial decision-making.  I find that male and female prosecutors exhibit small and statistically insignificant differences in their treatment of defendants overall but demonstrate relative leniency towards defendants of their own gender.  Such favoritism at charging translates into a sentencing gap of roughly five months of incarceration for defendants who are paired with an own-gender prosecutor versus an opposite-gender prosecutor, which represents a roughly eight percent reduction in sentence length at the mean.  The estimates do not appear to be driven by differences in case assignments for male and female prosecutors.

February 2, 2022 in Data on sentencing, Race, Class, and Gender, Who Sentences | Permalink | Comments (12)

February 1, 2022

Different perspectives one year after Measure 110 took effect decriminalizing low-level drug possession in Oregon

Via an email with this press release from the Drug Policy Alliance, I received a reminder that today marks one year since the effective data of Measure 110, Oregon's ballot initiative decriminalizing personal possession of all drugs.  The DPA release suggests there is much to celebrate on this anniversary:

While the robust support infrastructure is still getting off the ground, early results show over 16,000 people have already been able to access services. Additionally, there has been a nearly 60% decrease in the amount of people who have been arrested for any drug offense (approximately 3,700 drug offense arrests in the first 10 months after decriminalization took effect compared to over 9,100 arrests in the same 10-month period of 2020....

According to the first round of data from the Oregon Health Authority (based on grant reports from the Access to Care grants that went out last spring and summer — representing the initial $31.4 million previously mentioned — to 67 organizations and 11 tribes and tribal organizations), the funding has been used to:

  • Provide grant funding to 67 harm reduction, treatment, housing, peer support and recovery organizations across 29 counties
  • Provide funding to 11 Tribes and Tribal organizations through Tribal set aside
  • Provide services to 16,000 people, 60% of which engaged with harm reduction services
  • Hire 115 staff to provide a variety of health, harm reduction, treatment, housing and recovery services
  • Purchase 12 vehicles to provide mobile health and harm reduction services
  • Purchase three housing units - one motel, one duplex, and one gender and culturally-specific recovery house, plus 10 tiny houses
  • Secure four leases on new facilities
  • Purchase 154,535 harm reduction supplies
  • Pay for four 24-hour peer support and crisis phone lines

This Filter article reports on the one-year anniversary in a somewhat similar vein under the headline "One Year on, Oregon Drug Decriminalization Is Boosting Harm Reduction and Housing":

Housing is another particularly important need that Measure 110 is helping to address. “Not everyone’s going to get into residential treatment and not everyone needs residential treatment,” [Tera Hurst, executive director of the Health Justice Recovery Alliance] said. “Some people actually have better outcomes if you’re able to house them in their community and offer these ‘wraparound’ services.” 

Hurst acknowledged Oregon’s huge task of setting up the behavioral health resource network in 2022.  But advocates like her are also on the defensive — already, state lawmakers are making plans to take money allocated for expanding services and spend it instead on more police.

Challenges and battles remain, therefore.  But thousands of people in Oregon, whether receiving services or avoiding arrest, have already felt benefits from Measure 110. And with major funding soon to be rolled out, many more positive impacts are expected in 2022.

But some other media sources have a somewhat different perspectives on how things are going in Oregon.  This local press piece, headlined "As Meth and Fentanyl Tighten Their Grips on Oregon, the State Scrambles to Implement Treatment Services: Measure 110 will provide a massive infusion of new money but overdose deaths are skyrocketing," provides some sobering statistics:

The good news, Oregon State Medical Examiner Dr. Sean Hurst recently told lawmakers, is that the jump in Oregon’s alcohol-related deaths in 2020 flattened in the first half of 2021. The bad news: Drug overdose deaths, particularly those involving fentanyl and methamphetamine, soared to new highs.

Deaths attributable to meth jumped from 2019 to 2020, and are on pace for a bigger increase in 2021, Hurst told lawmakers Jan. 13. Though slightly less numerous, fentanyl-related deaths are rising much faster: They more than doubled from 2019 to 2020 and are on pace to rise steeply in 2021.  Together, medical examiner figures show, the two drugs will account for the deaths of more than 1,000 Oregonians in 2021 — that’s nearly three per day. “Substance use disorder is prevalent and it’s everywhere,” says Tony Vezina, chairman of the Oregon Alcohol and Drug Policy Commission.

Hurst presented his dismal news on drug deaths as the state races to implement Measure 110, the 2020 ballot measure that forced two major policy shifts.  It decriminalized the possession for personal use of many hard drugs, including heroin, meth, cocaine and some opioids. Measure 110 also shifted funding from Oregon’s cannabis taxes — well over $100 million a year — to fund new referral and treatment services for substance use disorder....

The idea was that those cited for possession could avoid a fine by calling a phone number on their ticket; that connection would open a gateway to evaluation and services—and get up to $100 of their fine waived. Data collected by the Oregon Judicial Department from February 2021 through Dec. 31, however, shows that avenue has not worked. Police wrote 1,826 tickets last year for hard drugs (nearly two-thirds for meth) but few — only 55 for the whole year — prompted users to telephone the number for services.

Advocates of Measure 110 say it will take time for the benefits to become apparent, as was the case in Portugal, which decriminalized hard drugs in 2001 and saw its overdose death rate plummet — but only after services were in place.

Tera Hurst, executive director of the Oregon Health Justice Recovery Alliance (and no relation to the medical examiner), says voters signaled they wanted an explicit shift away from treating people with substance use disorders as criminals and to instead direct energy and money toward treatment.  She says it’s unsurprising that citations are not driving drug users to seek help. She and other advocates did not expect they would. Even arrests rarely motivated users to seek treatment, they say — most go only when they are ready.

This other local press stories also set forth distinct perspectives on drug-related challenges in the Beaver State:

"Oregon is No. 2 in nation for addiction, last on access to treatment"

"Oregon’s drug decriminalization measure fails to fund treatment"

February 1, 2022 in Drug Offense Sentencing | Permalink | Comments (14)

Fourth Circuit panel upholds a "quirk" in Virginia’s sex-offender registry against various constitutional challenges

Though Justice Scalia passed away nearly six years ago, I still recall him preaching the simple (and perhaps controversial) idea that the Constitution does not always invalidate stupid laws. (Here is an account of a speech he gave 20 years ago at Princeton university where he said "the Constitution sometimes requires upholding a law that does not make sense.") The late Justice came to mind today when I saw the recent Fourth Circuit ruling in Doe v. Settle, No. 20-1951 (4th Cir. Jan 28, 2022) (available here). Here is how the lengthy unanimous panel opinion in Doe starts and concludes:

Two months after he turned 18, John Doe was caught having sex with his 14-yearold girlfriend.  Given the facts of his arrest, Doe may well have been charged with “carnal knowledge of a child,” a Class 4 felony that prohibits sex with 13- and 14-year-old children.  But instead he was charged with and pleaded to a lower-class felony, “taking indecent liberties with children,” which only prohibits behavior like propositioning a child for sex.  Doe’s plea may have gotten him a shorter prison sentence, but due to a quirk in Virginia law, it also led to worse treatment by Virginia’s sex-offender registry.  Both crimes generally put an offender on the highest tier of the registry for life, but there is a narrow exception to that rule.  When an offender is less than 5 years older than his victim, he may be removed from the registry in time.  But that mitigating exception only applies to carnal knowledge, the crime with the higher sentencing range, and not to indecent liberties.  So while Doe may have felt lucky to only be charged with indecent liberties, given the potential for a lower prison sentence, that plea ended up condemning him to worse treatment on the registry.  Because of that oddity, Doe will spend the rest of his life on Virginia’s sex-offender registry with no hope for relief.

Doe — now in his 30s — sued Colonel Gary T. Settle, Superintendent of the Virginia Department of State Police, hoping to persuade a court to remove him from that registry and its burdens.  Doe argues that the registry and the 5-year-gap provision violate multiple constitutional principles.  In his Fourteenth Amendment equal protection claim, Doe asks us to consider why an offender convicted of having sex with a child, as Doe might have been, should be treated better than an offender convicted only of propositioning a child for sex, Doe’s actual charge.  In his Eighth Amendment claim, Doe asks us whether a lifelong registration requirement is an appropriate sanction for a single nonviolent crime committed by a high-school student.

Both appeals present significant issues of fairness, but at bottom, they ask us to question the wisdom of the Virginia legislature and its sex-offender registry.  That is not our place.  When the Constitution is invoked, our place is to determine whether state laws comply with the specific dictates of that document.  And Virginia’s sex-offender registry complies with the Eighth and Fourteenth Amendments.  So we affirm the district court’s dismissal.....

If an 18-year-old man in Virginia has “consensual” sex with his 14-year-old girlfriend, and the next day, sends her a text message asking her to do it again, he will have committed two crimes.  But under the letter of the law in Virginia, only one of those crimes will place him on the worst tier of sex offenders on the registry with the rapists and the murderers: the text message.  That may not make much sense.

But our Constitution “presumes that even improvident decisions will eventually be rectified by the democratic process.”  See Cleburne, 473 U.S. at 440.  The judiciary is not meant to revise laws because they are clumsy, unwise, or — even in some cosmic sense — unfair.  In cases like this, courts are asked to make judgments about what is inside and what is outside the precise lines drawn by the Constitution.  And whatever else they may be, Virginia’s sex-offender registry and its narrow Romeo-and-Juliet provision are constitutional.  Accordingly, the district court’s judgment is AFFIRMED.

February 1, 2022 in Collateral consequences, Offender Characteristics, Offense Characteristics, Sex Offender Sentencing, Who Sentences | Permalink | Comments (4)

Consumer Financial Protection Bureau reports on "Criminal Justice Financial Ecosystem"

This official press release, fully titled "CFPB Report Shows Criminal Justice Financial Ecosystem Exploits Families at Every Stage: Report Finds Products and Services Rife with Burdensome Fees and Lack of Choice," summarizes a notable new publication from the government agency tasked with safeguarding consumer financial products.  Here are excerpts from the press release, which includes a link to the CFPB's new report:

The Consumer Financial Protection Bureau (CFPB) today published a review of the financial issues facing people and families who come in contact with the criminal justice system. The report, “Justice-Involved Individuals and the Consumer Financial Marketplace,”  describes an ecosystem rife with burdensome fees and lack of choice, and where families are increasingly being forced to shoulder the costs. It walks through the financial challenges families encounter at every stage of the criminal justice process, and the ways in which providers — often for-profit private companies — are leveraging a lack of consumer choice and their own market dominance to impose hefty fees at families’ expense.

“Many incarcerated individuals and their families pay exorbitant fees for basic financial services,” said CFPB Director Rohit Chopra. “Today’s report describes how private companies undermine the ability for individuals to successfully transition from incarceration.”

Contact with the criminal justice system is extremely common in the United States. In 2019, 2.1 million adults in America were in jail or prison, another 4.4 million were under community supervision (such as probation), and 1 in 3 adults — or 77 million Americans — had a criminal record.  Those figures do not reflect the family members and friends who often provide financial support to people who have been arrested, incarcerated, or released from jail or prison, and who are also affected by shoddy financial products and services entwined in the criminal justice system. The burdens of the criminal justice system — and its financial impacts — fall most heavily on people of color, and women and people with lower incomes of all races and ethnicities.  Surveys have repeatedly found women, and specifically Black women, disproportionately shoulder the costs of staying in touch with loved ones in prison and paying court-related debt for family members, sometimes spending up to a third of their income on such costs and even forgoing basic necessities for themselves.

Today’s report examines the financial burdens that can occur from arrest to incarceration to reentry.  It shows that as soon as families come into contact with the criminal justice system, they are confronted with numerous financial challenges, and that for-profit companies are embedded throughout.  Specifically, the report raises issues about:

  • Burdensome fees: Many local, state, and federal governments impose criminal justice debt on the people who interact with it in the form of fines, fees, and restitution.  The consequences of failing to pay fines and fees can be severe, forcing people to choose between making payments they may struggle to afford and risking arrest, prosecution, detention, or reincarceration.  States are also increasingly using third-party debt collectors to collect criminal justice debt.  These debt collectors can tack on additional fines and fees that, if not paid, can result in incarceration.
  • Lack of consumer choice: For incarcerated people and their families, the choice of financial service providers is limited throughout the criminal justice system. In a normal functioning market, products compete on price and quality, but all too often, government contracts in the criminal justice system mean just one choice for consumers....
  • Shifting financial burdens: Increasingly, governments are shifting the cost of incarceration to people who are incarcerated and their families, forcing individuals to pay for charges related to court operations, a court-appointed public defender, drug testing, prison library use, and probation supervision. People are also charged “pay-to-stay” fees for expenses related to their custody and care, like room and board, or medical copayments. When services are outsourced to private companies, the prices set by those companies are often wildly inflated over typical market costs. 

February 1, 2022 in Fines, Restitution and Other Economic Sanctions, Race, Class, and Gender, Reentry and community supervision | Permalink | Comments (0)

January 31, 2022

Federal judge rejects binding sentencing federal plea deal for men who killed Ahmaud Arbery

As reported in this new AP piece, a "federal judge rejected a plea agreement Monday that would have averted a hate crimes trial for the man convicted of murdering Ahmaud Arbery." Here are the sentencing details that apparently drove the decision:

A federal judge rejected a plea agreement Monday that would have averted a hate crimes trial for the man convicted of murdering Ahmaud Arbery.

Arbery’s parents denounced the proposed deal for Travis McMichael, with mother Wanda Cooper-Jones and father Marcus Arbery emotionally asking the judge to reject agreements filed for McMichael and his father, Greg McMichael.

In rejecting the deal, U.S. District Judge Lisa Godbey Wood said it would have locked her into specific terms — including 30 years in federal prison — at sentencing. Wood said that in this case it would only be appropriate to consider the family’s wishes at sentencing, which the proposed deal wouldn’t allow. The judge gave the McMichaels until Friday to decide whether they move ahead with pleading guilty.

Marcus Arbery told reporters outside the federal courthouse in Brunswick that he was “mad as hell” over the proposal, which lawyer Lee Merritt said could enable Travis and Greg McMichael to spend the first 30 years of their life sentences in federal prison, rather than state prison where conditions are tougher. “Ahmaud is a kid you cannot replace,” Arbery said. “He was killed racially and we want 100% justice, not no half justice.”

Cooper-Jones described the U.S. Justice Department’s decision to propose the plea deal despite her objections as “disrespectful.” “I fought so hard to get these guys in the state prison,” she said. “I told them very, very adamantly that I wanted them to go to state prison and do their time. ... Then I got up this morning and found out they had accepted this ridiculous plea.”...

The proposed plea agreements for the McMichaels were filed with the court late Sunday. There was no mention of a deal with their co-defendant, William “Roddie” Bryan. All three men were sentenced to life in prison on Jan. 7 after a trial last fall.

The hate crime charges accuse McMichaels and Bryan of violating the 25-year-old Black man’s civil rights by chasing him through their neighborhood in coastal Georgia on Feb. 23, 2020. The McMichaels armed themselves and pursued Arbery in one pickup truck while Bryan joined the chase in another and recorded video of Travis McMichael blasting Arbery with a shotgun.

January 31, 2022 in Procedure and Proof at Sentencing, Sentences Reconsidered, Victims' Rights At Sentencing, Who Sentences | Permalink | Comments (1)

"Life 'Or' Death"

The title of this post is the title of this new article authored by Marlee Russell now available on SSRN. Though focused on Mississippi law, the issue of "or" in state constitutions is one that arises in a number of other states. Here is this article's abstract:

This Article argues that the death penalty violates the Mississippi State Constitution because of the state’s prohibition of cruel “or” unusual punishments. By using the word “or” instead of “and,” Mississippi guarantees its citizens with a broader protection than the Eighth Amendment guarantees.  The different language should cause punishments, specifically the death penalty, to be evaluated under a separate standard for each prong of this protection.

Part I of this paper will argue that lethal injection is torture, explaining the methods, procedures, and associated risks during administration of the drugs.  Part II will show how lethal injection violates the Mississippi State Constitution due to the differences between conjunctive and disjunctive interpretations of the constitutional language.  Part III will prove that the remaining methods of execution in Mississippi violate the constitution because of their rare and unusual use in the state.  Part IV will suggest a new standard for evaluating if a punishment is cruel or unusual in Mississippi based on this language.

January 31, 2022 in Death Penalty Reforms, Sentences Reconsidered | Permalink | Comments (3)

Judge Ketanji Brown Jackson's distinct criminal justice background garnering attention as she tops SCOTUS short list

Long-time readers may recall that, six years ago after the surprise death of Justice Antonin Scalia, I started to talk up then-US District Judge Ketanji Brown Jackson as my favorite SCOTUS short-lister.  Though Judge Jackson was only 45 years old back in 2016 and had then served only three years as a federal district judge, I felt that her impressive professional history and especially her criminal justice experiences — as a federal public defender, as a member of the US Sentencing Commission, and as a sentencing judges — would make her an especially valuable addition to the Supreme Court.

Fast forward six years, and I still think now-US Circuit Judge Ketanji Brown Jackson would be a great pick for an open seat on the Supreme Court.  And because Judge Jackson now is on the very top of nearly every SCOTUS short list, major papers are already robustly covering her criminal justice experiences.  Specifically, this past weekend brought these two notable pieces:

From the New York Times, "For Ketanji Brown Jackson, View of Criminal Justice Was Shaped by Family; The story of an uncle’s cocaine conviction formed only part of Judge Jackson’s understanding of the system’s complexities; She is now seen as a contender to be President Biden’s Supreme Court pick"

From the Washington Post, "Possible Supreme Court nominee, former defender, saw impact of harsh drug sentence firsthand"

Both of these pieces focus a bit more on the personal than on the professional, but I suppose that is inevitably the main currency in these sorts of pieces.  I will be interested to see, in the weeks leading up to Prez Biden's selection and especially if Judge Jackson gets the nomination, how her professional history as a federal public defender and as a member of the US Sentencing Commission garners additional attention.  Interesting times.

January 31, 2022 in Criminal justice in the Biden Administration, Who Sentences | Permalink | Comments (12)

January 30, 2022

"Unraveling mass incarceration: Criminology's role in the policy process"

The title of this post is the title of this new article by Daniel Nagin in the journal Criminology.  This piece is adapted from an address delivered at the 2021 annual meeting of the American Society of Criminology in November 2021.  Here is its abstract:

In this address I argue that large reductions in unproductive and unjust uses of imprisonment requires curtailment of the over use of life imprisonment.  I go on to discuss how criminologists should engage the policy process to achieve material reductions in prison populations by the accumulation of many incremental reductions in the overuse of incarceration.

January 30, 2022 in Scope of Imprisonment | Permalink | Comments (0)

In week two of implementation of FIRST STEP earned-time credits, federal prison population drops another 550

As noted in this prior post from two week ago, the Department of Justice earlier this month announced its new rule for implementing "the Time Credits program required by the First Step Act."  I noted that, with DOJ providing for retroactive application of these credits, we could expect to see a decline in the overall federal prison population.  A week later, as noted here, on the first day the federal Bureau of Prisons updated it total inmate count, there was reported a roughly 2.5% drop in the federal inmate population (down to 153,855 "Total Federal Inmates" on January 20, from a count of 157,596 on January 13).  

On January 27, 2022, BOP updated here its report of "Total Federal Inmates," and that number now reads at 153,293.  So, during what might be called week two of implementation of FIRST STEP earned-time credits, the federal prison population dropped more than an additional 550 prisoners.  That is a big drop, though also a big drop off from the week one decline of nearly 4000 inmates.  Because the federal prison population was steadily creeping up throughout most of 2021 — from a low of 151,646 inmates as of January 21, 2021 — it will be interesting to watch just where the federal prison population might be headed the rest of this year.  

Prior recent related posts:

January 30, 2022 in FIRST STEP Act and its implementation, Prisons and prisoners | Permalink | Comments (0)