Sentencing Law and Policy

Friday funnies?: Turkish court imposes sentence of 11,196 years in prison!

I surmise that any number of things associated with cryptocurrencies, including lots of numbers, are unbelievable.  But this Bloomberg story, headlined "Boss of Failed Crypto Exchange Gets 11,000-Year Sentence," has a sentencing number I could hardly believe.  Here are the details:

Faruk Fatih Ozer, who ran crypto exchange Thodex until it imploded in 2021, was sentenced to 11,196 years in prison by a Turkish court for crimes including fraud. Delivering its verdict late Thursday, the court in Istanbul sentenced Ozer and his two siblings to similar-length jail terms, finding them guilty of aggravated fraud, leading a criminal organization and money laundering.

Ozer, a high-school dropout who founded Thodex in 2017 and fled to Albania after Thodex went bust, appeared unrepentant at his final hearing. “I am smart enough to lead any institution on Earth,” state-run Anadolu Agency cited Ozer as saying in court. “That is evident in this company I established at the age of 22. I wouldn’t have acted so amateurishly if this were a criminal organization.”

The total amount of losses investors suffered when Thodex collapsed remains unclear. The prosecutor’s indictment estimates them at 356 million liras ($13 million), but Turkish media have reported figures as high as $2 billion.

I know nothing about Turkish sentencing law and practice, but I do know anyone tempted to calculate average prison terms in that country is now going to come up with a very large number.

Split Louisiana Supreme Court finds Louisiana’s prosecutor-led review statute unconstitutional under state law

Thanks to a helpful reader, I saw that the Louisiana Supreme Court today issued a notable ruling that finds unconstitutional, as a matter of state constitutional law, a state statute that allowed prosecutors to petition for review of past convictions and sentences.  The majority opinion in Louisiana v. Lee, No. 2022-KK-01827 (La. Sept. 8, 2023) (available here), gets started this way:

We granted the writ application in this case to address an issue of constitutionality: whether Article 930.10 of the Code of Criminal Procedure, which governs post-conviction plea agreements, violates the state constitution’s separation of powers provision, La. Const. art. II, § 2.  More specifically, the question presented is whether Article 930.10 permits the judicial branch to exercise the governor’s power under La. Const. art. IV, § 5(E) to pardon a final conviction.  We hold that because Article 930.10 permits a court to overturn a final conviction without a finding of legal defect pursuant to La. C.Cr.P. art. 930.3, the article unconstitutionally allows the judicial branch to exercise the governor’s exclusive pardon power, and, therefore violates the doctrine of separation of powers as found in La. Const. art. II, § 2.

Though I am not an expert on Louisiana law, the close of the majority opinion seems to suggest that prosecutor-supported motions for resentencing would be possible in some cases if tethered to another provision of Louisiana procedure:

[O]ur decision does not mandate that collateral review of criminal convictions be unnecessarily adversarial, nor does it serve as a bar to cooperation between parties in post-conviction proceedings to achieve the ends of justice.  Such a mandate would be inconsistent with Article 2 of the Code of Criminal Procedure, which instructs that the Code is “intended to provide for the just determination of criminal proceedings,” and the provisions “shall be construed to secure simplicity in procedure, fairness in administration, and the elimination of unjustifiable delay.” See also State v. Shallerhorn, 2022-1385, pp. 6–7 (La. 6/27/23), --- So.3d ---.  A court’s ruling on a collateral challenge to a final conviction may follow an adversarial hearing, an unopposed presentation by the defendant, or a joint effort by both parties to convince the court that the law and evidence support vacating the conviction.

Our decision does mandate that courts overturn a final conviction only after finding a ground for relief enumerated in La. C.Cr.P. art. 930.3.  Were a court to vacate a conviction without such a finding, as is permitted by Article 930.10, it would amount to an unconstitutional exercise of the governor’s exclusive pardon power in violation of the doctrine of separation of powers as provided in La. Const. art. II, §2.

A lengthy and short dissent followed the majority opinion, and the closing passages of the long dissent by Justice Weimer speaks to some of the broader issues implicated here:

Any concern over the court usurping the pardon power by reducing a sentence is relieved by the codal requirement that the district attorney and the defense jointly agree, and by the fact that the district court judge is given the authority thereafter to determine if the joint motion will be granted.  It goes without saying that the discretion afforded to the district court will only be exercised if the facts demonstrate that justice and the interests of the society warrant the court’s decision.

The importance of La. C.Cr.P. art. 930.10 cannot be overstated. Louisiana incarcerates more citizens per capita than any state in the Union and any nation in the world. Non-unanimous juries exacerbated the problem and increased these numbers.  It is well-documented that the poor and minorities have been disproportionally impacted by the ill-conceived practices of the past.  Perhaps as a direct consequence, Louisiana experiences a significant number of exonerations of incarcerated individuals.

The post-conviction legislation at issue here was unanimously enacted by the legislature, the people’s representatives, and signed into law by the governor.  Its obvious purpose is to insure justice is done and to act as a counter balance or check on the renegade practices and prejudices of the past.  It will only afford a postconviction remedy in those matters in which an individual is proven to be not guilty of the crime charged and is designed to right wrongs in certain specific cases.  The legislature was obviously concerned about past practices and the ineffectiveness of the poorly developed post-conviction relief procedures.  Carried to its logical conclusion, the attorney general’s effort could have the disastrous effect of undermining, and further limiting, the post-conviction relief procedure that has operated to correct the evils of the past.  Finality for finality’s sake is an important concept, but our system of justice and our sense of fairness recoil at the thought that an innocent person remains punished for a crime not committed.

The multi-step process established by Article 930.10 is replete with checks and balances, requiring opposing sides to agree.  Just as the governor is granted authority to commute sentences, the district attorney is charged with prosecuting cases and the courts are charged with deciding cases properly brought.  The attorney general is seeking to strip the district attorney and judiciary of authority to resolve injustice on a case-by-case basis.  The decision of the district attorney and defendant to bring this case to the court is not commutation from a constitutional standpoint, which is wholly within the authority of the governor, but the resolution of a case that was carefully reviewed by the district attorney.  After that careful review here, the district attorney obviously determined that it was not in society’s best interest to spend untold resources in trying this matter. Rather, exercising the prudence and discretion afforded to his office, the district attorney determined the additional facts presented by defendant here dictated the agreed-upon resolution, which the district court evaluated and granted, promoting judicial economy and saving other valuable public resources.  That is not a commutation by the governor but the resolution of a case.  Such an interpretation of Article 930.10 is reasonable and does not result in a violation of separation of powers. See LeCompte, 406 So.2d at 1311 (on reh’g).  Accordingly, I respectfully dissent from the majority’s reversal of the district court’s June 15, 2002 ruling, as I believe that La. C.Cr.P. art. 930.10 is not facially unconstitutional and is, in fact, constitutional, as applied in this case.

New CRS document explores "Supreme Court’s Narrow Construction of Federal Criminal Laws"

The Congressional Research Service has this notable new "Legal Sidebar" reviews past and recent Supreme Court rulings that limit the scope of federal criminal statutes. This six-page document gets started this way:

Criminal law marks a boundary between conduct that society deems permissible and behavior that it deems worthy of punishment.  Those who cross the line may be subject to penalty and social disapproval.  In addition to punishment, transgressors may face wide-ranging collateral consequences, among other things.

Defendants charged with criminal offenses have mounted various legal challenges to the line drawn by criminal law itself.  One category of legal challenge centers on arguments related to where or how the boundary between lawful and unlawful conduct is established.  For example, defendants have argued that certain criminal statutes are unclear and fail to give fair notice to the public as to what conduct is wrongful; that other criminal statutes improperly reach those with no awareness that they have crossed the line and thus fail to reserve criminal punishment for those who are truly culpable; and that the application of particular criminal statutes in individual circumstances strays beyond what Congress intended or clashes with countervailing constitutional values.

In recent years, the Supreme Court has issued a series of decisions agreeing with defendants that have raised each of these arguments, narrowly construing some criminal statutes in the process.  A federal appellate judge described these rulings as “nearly an annual event.”  In the Court’s latest term, the Justices again issued opinions limiting the reach of specific criminal statutes.  This Sidebar addresses this apparent Supreme Court trend, identifying the substantive reasons why the Court has limited the scope of criminal statutes and offering examples from historic and modern cases.  The discussion and examples are not comprehensive but are representative in nature.  The Sidebar also summarizes four cases from the recently concluded 2022 Supreme Court term — Counterman v. Colorado, Dubin v. United States, United States v. Hansen, and Twitter v. Taamneh — in which the Court narrowly construed the criminal laws and concepts at issue.  The Sidebar closes with considerations for Congress.

Prez Biden reportedly involved in rejecting plea deal terms for 9/11 defendants

As reported in this New York Times piece, "President Biden has rejected a list of proposed conditions sought by the five men who are accused of conspiring in the Sept. 11, 2001, terrorist attacks in exchange for pleading guilty and receiving a maximum punishment of life in prison, according to two administration officials."  Here is more about reported presidential involvement in the prosecution of notorious criminals:

An offer by military prosecutors, made in March 2022, that would spare them death sentences if they admitted to their alleged roles in the hijackings, remains on the table, officials said. But Mr. Biden’s decision to reject additional conditions lessens the likelihood of reaching such a deal....

The White House was asked to weigh in on a proposed plea agreement about a year and a half ago. In talks with prosecutors, defense lawyers said Khalid Shaikh Mohammed, the accused mastermind, and four other defendants wanted certain accommodations, including assurances they would not serve their sentences in solitary confinement and could instead continue to eat and pray communally — as they do now as detainees at Guantánamo Bay.

The prisoners also sought a civilian-run program to treat sleep disorders, brain injuries, gastrointestinal damage or other health problems they attribute to the agency’s brutal interrogation methods during their three to four years in C.I.A. custody before their transfer to Guantánamo Bay in 2006.

An agreement to meet such conditions for the detainees, potentially for the rest of their lives, carried major policy implications likely beyond the authority of a criminal court or a particular team of prosecutors.

But the White House has been leery of involvement in the case, which is politically fraught. Some relatives of the 3,000 victims want a trial with the prospect, however distant, of having the perpetrators of the worst terrorist attack on U.S. soil sentenced to death. Others oppose the death penalty on principle, have no faith in the tribunal system, or have become resigned to the idea that, because the defendants were tortured by C.I.A., capital punishment is unlikely.

More than a year passed as prosecutors awaited an answer on whether the administration would consent to the proposed conditions, referred to as joint “policy principles” in court filings. A filing on Wednesday, which came just days before the 22nd anniversary of the attacks, indicated that the administration had finally said it would not.

“The administration declines to accept the terms of the proposed joint policy principles offered by the accused in the military commissions case, United States v. Mohammed, et al,” prosecutors said in the filing, according to someone who had been shown a copy. It was not yet posted on the Pentagon’s war court website.

Mr. Biden, according to the officials familiar with the matter, adopted a recommendation by the defense secretary, Lloyd J. Austin III. The court filing does not offer a rationale for rejecting the proposed conditions, according to the officials, who spoke on the condition of anonymity to discuss the sensitive matter.

One official said Mr. Biden did not believe the proposals, as a basis for a plea deal, would be appropriate, and the other cited the egregious nature of the attacks. But Mr. Biden took no position on the general notion that a plea deal could eliminate the possibility of death sentences. At a military commission, a senior Pentagon official, called a convening authority, oversees the cases and decides such questions....

Prosecutors had been explaining the mechanics of admitting guilt in court proceedings in exchange for life sentences in meetings with small groups of family members in New York, Boston and Florida since at least May. They sent out a two-page letter to reach a wider group last month. “It cannot be overstated that a guilty plea is conclusive evidence of guilt,” it said.

The possibility of a deal stirred emotions among the relatives of the victims of the Sept. 11 attacks — both those who envisioned a trial and death sentence and those who wanted a resolution that would not face the possibility of an appeal.

"Mandatory Minimum Sentencing, Crime, and Mass Incarceration: The Case of Mississippi"

The title of this post is the title of this new article authored by Mehdi Barati now available via SSRN. Here is its abstract:

The high rates of incarceration and the substantial financial and societal burdens associated with them have prompted state lawmakers to undertake measures to reduce prison populations.  Mississippi, however, has taken a somewhat different approach compared to other states.  In 2014 it passed House Bill 585, which introduced "true minimums" that require both nonviolent and violent offenders to serve a minimum of 25 and 50 percent of their sentence, respectively. This distinction makes the case of Mississippi particularly interesting, providing an opportunity to examine the impact of mandatory minimum sentencing on crime and incarceration rates.  Toward this end, this study employed both difference-in-differences and synthetic control methodologies to evaluate the effectiveness of House Bill 585.  According to the findings, the initial decline in the imprisonment rate resulting from the reforms was not sustained over time.  Moreover, House Bill 585 not only failed to effectively reduce violent crimes but was also found to be associated with an increase in property crimes in Mississippi.

Council on Criminal Justice releases new policy roadmap encouraging alternatives to prosecution and incarceration for justice-involved veterans

Via email, I learned today of an exciting and impactful new report from the Council on Criminal Justice’s Veterans Justice Commission. Here are all the details and links via the text of the email:

CCJ’s Veterans Justice Commission today released a policy roadmap that encourages states and the federal government to expand alternatives to prosecution and incarceration for justice-involved veterans.
 
The policy framework outlines alternative sentencing options that not only recognize veterans’ service, but also that their criminal behavior may have been influenced by that service.  The options, which include expanded use of pretrial supervision and probation in lieu of a record of conviction or incarceration, are grounded in evidence-based practices used in problem-solving courts and community supervision.  The Commission also encouraged jurisdictions to pass laws enabling veterans whose cases are processed through such options to file for record expungement.
 
“We are prosecuting and imprisoning veterans while denying them the care and consideration they need and deserve — despite the fact that their criminal justice involvement is often due, at least in part, to their willingness to fight for their country,” Commission Chair and former U.S. Defense Secretary Chuck Hagel said.  “As a result, we are not only doing a disservice to veterans, but also jeopardizing the safety of the public they once fought to protect.”
 
Based on the policy framework, the American Legislative Exchange Council (ALEC) in August adopted as model policy the Veterans Justice Act.  This version of the framework will be shared with state legislatures as a blueprint for action on the issue.

The policy framework reflects an initial set of recommendations released by the Commission in March.  Additional recommendations targeting veterans’ transition from service to civilian life will be forthcoming early next year. In addition to Hagel, Commission members include former Defense Secretary and White House Chief of Staff Leon Panetta, a former Sergeant Major of the Marine Corps, the chief justice of the Georgia Supreme Court, two formerly incarcerated veterans, and other top military, veterans, and criminal justice leaders.

Prior related posts:

• New CCJ commission to examine factors driving veterans' involvement in criminal justice system 
• Noting the notable challenge of defining "veteran" for various purposes connected to criminal justice systems 
• CCJ's Veterans Justice Commission releases "Honoring Service, Advancing Safety: Supporting Veterans From Arrest Through Sentencing" 

"Collusive Prosecution"

The title of this post is the title of this recent article I just came across via SSRN and authored by Ben McJunkin and J.J. Prescott. Here is its abstract:

In this Article, we argue that increasingly harsh collateral consequences have surfaced an underappreciated and undertheorized dynamic of criminal plea bargaining.  Collateral consequences that mostly or entirely benefit third parties (such as other communities or other states) create an interest asymmetry that prosecutors and defendants can exploit in plea negotiations.  In particular, if a prosecutor and a defendant can control the offense of conviction (often through what some term a “fictional plea”), they can work together to evade otherwise applicable collateral consequences, such as deportation or sex-offender registration and notification.  Both parties arguably benefit: Prosecutors can leverage collateral consequences to extract greater punishments and defendants can avoid consequences they view as particularly burdensome. But these benefits can come at a cost to others who are not at the bargaining table.

We contend that “collusive prosecution” of this sort can be pernicious, as may be the case when sex-offender registration and notification laws are in play, but it also has potential to be socially attractive.  Accordingly, we sketch a normative framework for evaluating collusive prosecution as a matter of prosecutorial ethics.  We draw on the emerging field of public fiduciary theory to characterize prosecutors’ ethical duties to varied — and often conflicting — beneficiaries.  We suggest that programmatic uses of collusive prosecution may be fair and reasonable in a common immigration context, but collusive prosecution designed to relocate sex-offense registrants likely fail these conditions. Ultimately, we offer a suite of reforms that may be useful for policing collusive prosecution without banning the practice outright.

Proud Boys leader, Enrique Tarrio, sentenced to 22 years for his role in Jan 6 activities

As reported in this Politico piece, "Enrique Tarrio, the national leader of the Proud Boys on Jan. 6, 2021, was sentenced Tuesday to 22 years in prison for masterminding a seditious conspiracy aimed at derailing the transfer of power from Donald Trump to Joe Biden."  Here is more:

The sentence, the lengthiest among hundreds arising from the Jan. 6 attack on the Capitol, is a reflection of prosecutors’ evidence that the Proud Boys, helmed by Tarrio, played the most pivotal role in stoking the violent breach of police lines and the Capitol itself. “Mr. Tarrio was the ultimate leader of that conspiracy. Mr. Tarrio was the ultimate leader, the ultimate person who organized, who was motivated by revolutionary zeal,” U.S. District Court Judge Timothy Kelly said as he handed down Tarrio’s sentence. “That conspiracy ended up with about 200 men amped up for battle encircling the Capitol.”

Hundreds of Proud Boys from across the country, vetted and assembled by Tarrio and a group of top lieutenants, became a vanguard of sorts as a mob of Trump supporters descended on the Capitol, and members of the group were involved in nearly every breach of police lines that day.  Dominic Pezzola, a New York Proud Boy who triggered the breach of the Capitol itself by smashing a Senate window with a stolen police shield, was sentenced Friday to 10 years in prison.

Tarrio, unlike most of his co-conspirators, was not at the Capitol on Jan. 6. Upon his arrival in Washington on Jan. 4, 2021, he was arrested for his role in the theft and burning of a Black Lives Matter flag from a church after an earlier pro-Trump march. Tarrio was released the next day and ordered to leave Washington D.C., so he headed with a group of allies to a hotel in Baltimore.

Prosecutors say despite his absence, he remained in touch with his men and monitored their actions on Jan. 6. And after the attack, he repeatedly celebrated the attack, defended his allies and regretted that it didn’t fully derail the transfer of power. He was convicted in May of seditious conspiracy, conspiring to obstruct Congress’ proceedings and destroying government property, among other charges.

Tarrio’s sentence closes a significant chapter in the investigation of the Jan. 6 attack. His 22-year sentence is likely to remain the lengthiest for anyone charged in connection with the attack itself — a mark that exceeds the 18-year sentences handed down to Oath Keepers founder Stewart Rhodes and Tarrio’s ally Ethan Nordean....

Kelly, a Trump appointee, appeared largely unmoved by Tarrio’s words of contrition. He emphasized that as the attack unfolded, he used his platform to tell his allies “Don’t fucking leave.” And that night, Tarrio privately told a confidant, “Make no mistake. We did this.” Despite Tarrio’s contrition, Kelly again slammed him for comparing Pezzola to George Washington. “It slanders the father of our country to speak that way,” Kelly said. The judge added that he doesn’t see evidence, despite Tarrio’s apologies, that he feels remorse for the seditious conspiracy for which he was convicted.

Notable new resource provides "Data for Defenders"

Though I am institutionally disinclined to praise anything emerging from the school up north, I am still quite pleased to highlight and compliment a new UM resource brought to my attention by Eve Brensike Primus, who is a Prof at the University of Michigan Law School and Director of the Public Defender Training Institute.  Here is the full description from an email I received earlier today:

Data for Defenders is a new database that collects briefs, motions, and transcripts focused on social science research and data helpful to public defenders. It includes information on topics like the science of eyewitness memory; problems with racism and bias in the criminal legal system; and the use of unreliable, seemingly scientific evidence.

The project is sponsored by the University of Michigan’s MDefenders program along with a number of partners — including public defender offices and organizations around the country — to ensure that the database remains relevant and up to date.  In addition to including completed briefs and motions submitted by defenders, defense experts at Michigan Law will regularly draft language for new briefs and motions, incorporating novel social science research to help defenders advocate with and for their indigent clients.

The database is organized in a user-friendly way. For every document in the database, there is a description that will pinpoint exactly which pages have the relevant information. It’s also searchable by a number of different categories — date, jurisdiction, topic, key terms.  And because it has succinct summaries, perusing the database by category can also generate ideas for defenders about different kinds of issues they can raise that they might not have thought of.

Instead of having defenders around the country waste precious time reinventing the wheel, this database will collect and share sample motions and briefs to help public defenders bring data, research, and statistics into the courtroom.  We encourage you to take a look at this new resource, use it when helpful, and contribute materials to it.  And if there are subjects that you’d like to see covered that are not currently included, feel free to send your ideas to mdefendersinfo @ umich.edu.

I noticed that two of the documents in the database are on sentencing, and I am sure there are also others that will be of interest to sentencing fans.

Guest post: "A plea for juries — at sentencing"

I am very pleased to have the opportunity to publish this guest post from Marah Stith McLeod, who is a Associate Professor at Notre Dame Law School and the authors of a number of great sentencing articles.  I am grateful to be able to platform here a brief account of her latest article, "A Democratic Restraint on Incarceration" (which I first flagged in this post):

Several recent postings on this blog have focused on the value of juries as organs of democratic self-governance. Americans retain an abiding trust in juries as legitimate decisionmakers — far higher than the trust they place in judges, prosecutors, and defense attorneys. Serving on a jury, moreover, tends to increase the jurors’ understanding of, and trust in, the criminal justice system, and tends to make jurors afterward more likely to participate in civic life. 

We have in recent years witnessed significant challenges to American democratic institutions and a loss of confidence in the competence and ethics of our elected leaders.  In a recent guest essay in the New York Times, Wharton organizational psychologist Adam Grant argued that if we want more effective and ethical leaders, we should choose them not by election but by sortition — by random selection from a pool of candidates.  Grant proposes a system in which laypeople who pass a civics test can join the candidate pool.

We should take Grant’s proposal seriously.  Fortunately, as Grant observes, “we already use a version of a lottery to select jurors,” and criminal juries have historically played crucial roles in promoting a just and flourishing civil society. Justice Sonia Sotomayor recently described juries as “democratic institutions called upon to represent the community as ‘a bulwark between the State and the accused.’”  When it comes to reforming our criminal justice system, juries may be exactly the kind of democratic institution we need most.

Juries’ current role as finders of fact, however, is not enough.  Juries also should have the power to limit penalties — especially the decision to strip a defendant of his liberty and suspend his civic existence.  Elected politicians may be voted out of office if they vote to reduce criminal penalties, and judges have powerful incentives to maintain a trial penalty in order to induce future defendants to plead guilty.  The jury is free of these punitive incentives.  And legislatures may find it much easier to allow juries to impose constraints on punishment, because juries enjoy unusual levels of public trust and make only case-specific decisions.

In A Democratic Restraint on Incarceration, I argue that trial juries should be empowered to set an absolute maximum amount of incarceration based on what a defendant deserves, and the trial court’s sentencing discretion should be capped at that amount.  Sentencing courts could sentence below jury-set maximum desert, but never above it. Legislatures should grant juries case-specific authority to depart even below mandatory minimums in order to avoid undeserved excesses.

A skeptic might doubt juries can make a real difference in a criminal system dominated by plea deals. But the effects of a new jury power to constrain post-trial penalties would reverberate across pleaded cases as well, for prosecutors could no longer credibly threaten defendants with post-trial prison terms that no jury would deem to be deserved. Defendants would gain a valuable bargaining chip, and prosecutors would lose an unjust tool, correcting — if only slightly — the imbalance of power in plea negotiation.

The unique trust the public places in juries makes them ideal institutions to restrain carceral excesses.  Rather than waiting for our elected officials to repeal or mitigate unjust penalties, we should let juries take the lead.

A hot, long reading list for a hot, long (last?) summer weekend

The hot weather this weekend, at least on the east coast, makes it feel like we are still in the middle of summer.  But with college football and law school classes now in full swing, the Labor Day weekend certain has an end-of-summer feel.  Because I am on the road this weekend, I do not have time for full seasonal reflections, though I can assembled some interesting recent crime and punishment readings:

From AL.com, "Here is how Alabama plans to carry out first nitrogen hypoxia executions in the nation"

From The Marshall Project, "Ending the Golden State Era of Solitary Confinement"

From The Messenger, "Republicans Should Lead by Listening to the Voters on Criminal Justice Reform"

From The Nation, "Progressives Need to Have Real Answers on Crime"

From the New York Daily News, "Jeffries pushing to expand eligibility for expunging first-time minor drug convictions"

From the New York Times Magazine, "The Dungeons & Dragons Players of Death Row"

From The New Yorker, "Listening to Taylor Swift in Prison"

From PBS News Hour, "Departing governor races to move prisoners off death row in Louisiana"

From Phsy.org, "How Norway is helping to restore humanity inside US prisons"

From Reason, "Federal Prison Guards Confessed to Rape and Got Away With It"

From RedState, "The First Step Act Is a Resounding Success so Far"

From the Sacramento Bee, "Thousands of California inmates are sentenced to die in prison. Should some get to seek parole?"