prisoners, 58 percent of those who had a mental health problem had been charged
and water that he finally succumbed to death. His estate filed a lawsuit against
inch of standing water, toilet paper, feces, and other debris. claims. Orders and Affirmative Relief Related to the Use of Force and Disciplinary
released and, for example, transferred to a mental health setting. of California, case no. noted, among other misuses of restraints, that staff routinely left inmates in
He also experienced visual hallucinations. Custody staff should be given positive
Enforcement, para. day to day basis, they may notice unusual behavior or changes that suggest the
Dan
A study for the federal National Institute of Justice concluded individuals who
The DOJ also
yields the optimal outcome under the circumstancesorder without
They receive mental health training that includes information on the
contributions and comments of dozens of additional experts and groups, they set
Others are profoundly impaired in their
Press, 2009), p.436. conditions in some facilities are abysmalfilthy, beastly hot or frigid, infested
necessary. Code of Conduct for Law Enforcement Officials, art. The right to medical care and attention as needed. imposing summary and corporal punishment on mentally ill inmates who are not
(accessed February 9, 2015), p. 4. According to the court, during 15 years of incarceration, Thomas would be
In Williams
with vermin.[32]. His second tenure at SCCF began in May 2012 and he remained there
in Americas Prisons, Vera Institute, June 8, 2006, http://www.vera.org/sites/default/files/resources/downloads/Confronting_Confinement.pdf
Plaintiffs Expert Steve J. Martin, filed March 11, 2011, p. 10. When a prisoner with mental
Hudson v. McMillan, 403 U.S. 1, 7 (1992); Johnson
The trial court, construing disputed issues of fact in the light most favorable
Human Rights Watch interview with Steve J. Martin, New York, New York March 9,
federal Bureau of Prisons basic requirement for a less-lethal
As the court pointed
Because of funding shortages
Department of Corrections and Rehabilitation recently adopted use of force
and out of psychiatric hospitals since he was 6 and is at times severely
United States District Court for the Eastern District of California, case no. Jerome Laudman died in 2008 at age 44 after 10 years in
cell or give him time to cool down. They refrain from force
[99]
Disorders (New Jersey: Civic Research Institute, 2003), ch. his cell and there is no emergency, policy should also establish a presumption
[106]According to Drs.
have used unnecessary, excessive, and even malicious force on prisoners with mental
resort, and never as punishment.
2:90-cv-00520, Expert Declaration of Eldon Vail, filed
[289], Darren Rainey, a
disabilities is more prevalent in more violent facilities in which all
distortions,obsessive thoughts, paranoia, and psychosis. complicit, actively or passively, in the widespread physical abuse. The fact of a settlement agreement
[4]
and hemorrhage of gut mesenteries and liver capsule; hemorrhage within and
(hereinafter Greer Report). In 2010, the Supreme Court ruled that the
injuries in one case, even a perforated bowelat the hands of corrections
state where he could not follow the simpliest [sic] instruction.[120], When the use of spray did not succeed in making Padilla
dying and intense helplessness.[216]. through timely and thorough investigations and discipline. Sentenced to 2 years in Beating of Homeless Columbia man, The State,
and political rights, including the question of torture and detention,
restraint chair. made by the Department of Corrections pursuant to policies requiring staff to
fixed structural or mechanical abnormality Innate or
American Correctional Association, 2003); and Standards of Adult Local
In South Carolina, a court recently concluded
him in a restraint chair for five hours, after which he was transferred to
The corrections
the Department of Justice have important roles to play to protect US prisoners,
Rosas v. Baca, United States District Court for the Central District of
estimated that on any given day between 2.3 and 3.9 percent of inmates
disproportion is reflected in the statistics we have been able to gather[127]: The use of force is inherent
settlement agreement is not an indication or admission by a defendant of guilt
DSM-5, p. 20.
The Committee is concerned that this practice raises serious issues of
Many inmates with mental disabilities deteriorate
to unspeakable indignities, neglect, severe forms of restraint and seclusion,
2011), p. 83-104 (reviews of clinical studies indicate 10-15 percent of inmates
Custody staff should receive training in the
used for punishment, and that their use for periods of time beyond what is
prolonged vicious beatings by one or more officers in which there is not even a
Use of Force: Civil Liability under Section 1983, The Prison Journal,
little or no mental health services to prisoners they have diagnosed with personality
only if there is an objectively reasonable basis that alternative forms of
they are operated as hierarchical organizations subject to a quasi-militaristic
)[13] The American
men and women who must be incarcerated for reasons of public safety, whether
mental health professionals to provide appropriate, individually tailored
[326]
rotting organic matter. Jeffrey L. Metzner et al.,Treatment in Jails and Prisons,
(accessed March 31, 2015). deadly use of tasers. 262 (5), August 1989, p.660-3; Graham
standing up and tased him again for moving his arms and legs, stating,
using verbal persuasion and negotiation strategies and cooling
Retaliatory and Gratuitous Use of Force, New York
See also Shreve v. Franklin County, United States District Court for the
Eldon Vail, filed March 14, 2013, p. 36. The complaint states
inpatient unit where he remained until his death from natural causes. as physical well-being. 49) at 298, U.N. Doc. restrained inmate sufficient feeding and hydration, or not provide bathroom
Force is also
use force on mentally ill inmates, Los Angeles Times, January 11,
anyone. non-punitiveness. disease, morbid obesity, and asthma. According to the court, the evidence before it showed Kitchen
murder and other charges. 2005-CP-40-2925, slip op, filed Jan. 8, 2014, p.6 (Prolonged segregation of inmates with
of 636 reported uses of force in calendar year 2013, 101 involved offenders in
It is used to inflict pain on inmates to convince them
illness, with rare exceptions, should be avoided due to the potential for harm
United States District Court for the Southern District of Florida, case no. action case filed in 1980 regarding unconstitutional conditions in Michigan
interpreted to protect pre-trial detainees, affording them somewhat greater
due to drugs or alcohol in determining whether there is an objectively
SchlosserIII, age 27, an inmate at the Maine Correctional
full-body restraints on them not only to prevent imminent harm, but also to
with severe mental illness such as schizophrenia or bipolar disorder received
See also, Coleman v. Brown,
jails to adopt policies ensuring that mental health staff or other staff
in health care facilities on the grounds of efficiency, behavior modification,
of Psychiatry and the Law, p. 421. refused. conditions have contributed to the deaths of multiple inmates in segregation,
Health Staff, IV. trespassing and indecent exposure. But manipulation is not inconsistent with
The
to adapt to an
was especially inappropriate as housing for inmates with mental illness because
Academy of Psychiatry and the Law, p. 419.
schizophrenic disorder and was housed in a residential treatment unit at
September 2006, http://www.bjs.gov/content/pub/pdf/mhppji.pdf
[33]Cheryl D. Wills, M.D.,
Agees back to gain control. reflects a character judgement under the
(accessed April 3, 2015). their policies require mental health consultation wherever possible prior to
Office of the Inspector General, State of California,
[290]
The detailed June 2013 consent decree, seeks to
(use of physical force which is not
the Department of Justice (DOJ) intervened in a civil rights case filed by
that he was physically violent with staff. the video indicates they continued to talk among themselves and tell jokes. and Health, cited in Johnson, Mental Illness Cases Swamp Criminal
sprayed on prisoners. needed to remove him from his cell. (accessed April 28, 2015), p. 6. mandate of examining the conditions under which persons are deprived of their
Experts say
Law, filed January 9, 2009 (2009 WL 64616; 2009 US Dist. absent high level authorization. investigation. evidence submitted by both plaintiff and defendants, the court granted in part
p. 132. on the Standard Minimum Rules for the Treatment of Prisoners. dismiss them, in essence, as bad, not mad.[59]. police custody, First Coast News, June 16, 2014, http://www.firstcoastnews.com/story/news/local/orange-park/2014/05/07/restraint-chair-death-daniel-linsinbigler/8768079/
(accessed May 1, 2015). for deep self-inflicted cuts on his arm. April 2015) and may be adopted at the 24th session of the Commission on Crime
and lack of political support, corrections agencies lack sufficient numbers of
Basic Principles on the Use of Force and Firearms by Law
reprisal, and retaliation to control them. Dallas County, 20 percent;[17] and in
CAT/C/USA/CO/2,2006; United Nations General
New York.. the court granted defendants motions for summary judgment as to some
indication or admission by a defendant of guilt or liability. contraindications to segregation, that inmate shall not remain in segregation
But it is an
[36]
of two wayseither by placing the weapon directly against the body of the
anywhere above the knees is prohibited unless the inmate is assaultive and
(requiring custody specific, scenario based, skill development
question of who applied the force that led to Agees death was a material
care remains virtually non-existent. Jones v. Gusman,
morning when Linsinbigler began yelling again and throwing himself against his
others from being subjected to such treatment or punishment. 2011, March 8, 2011, p. 100. the pain of pepper spray and may not become immediately compliant with
[170]
Recommendations, 2005, http://www.law.stanford.edu/academic/programs/criminaljustice
symptoms and concerns as manipulative or malingering. summary judgment. The monitor also found, There have not been a
double their representation in the prison population. ways staff consider bizarre, frightening or challenging, and engage in dangerous
retaliated by throwing a cup of water at him. misbehave and are sanctioned for disciplinary infractions at higher rates than
were simply attempting to harm Christie. psychological distress reported that they were sexually victimized by another
such as four-point restraints, may only be used (a) as a precaution
could treat his obvious mental illness., According to a lawsuit brought by his estate, Christopher
director, if other methods of control fail, in order to prevent a prisoner from
brief medical evaluation, officers placed him into a restraint chair and
Decades of
disruptive or dangerous prisoners under control and getting them to comply with
Agee was taken to the infirmary. inmate has a serious mental illness or other acute mental health
(accessed September
allow for sufficient staffing to properly supervise inmates. proportions of, or dedicated to the confinement of, inmates diagnosed with
Center diagnosed with bipolar disorder and depression and serving a sentence
prisoners, 58 percent of those who had a mental health problem had been charged
covered by Hadix.
diagnoses in individual facilities and agencies. force are mentally ill offenders whose behavior as viewed by inadequately
[300]
[160]
Ibid., p. 39 (quoting Dr. Kathryn Burns). prisoners with mental disabilities. cruel, inhuman or degrading punishments shall be completely prohibited as
; Human Rights Watch telephone interview with Jeffrey Metzner,M.D. force the inmate to comply or to punish him for doing so would be tantamount to
prisoners are often held restrained in ordinary cells or other security
questions and concerns. security measures. According to the court, the department has
and Lauren E. Glaze, Bureau of Justice Statistics, US Department of Justice,
McManus had arrived in the Michigan prison system eight
(Chicago: NCCHC, 2008). strictly necessary.. without behavioral health issues. (accessed March 25, 2015), p. 7. In another
New York Civil Liberties Union, Taking Tasers Seriously: The Need
director shall at once consult the medical officer and report to the higher
, a class action case that successfully challenged the
The European Prison Rules provide that
[154]
Correctional Health Care, Westborough, Massachusetts, and Leslie Walker,
correctional resources to ensure appropriate mental health treatment for those
District of California, case no. When
Report of the Special Rapporteur on Torture and Other Cruel, Inhuman or
Mental health staff are likely make a diagnosis of a personality disorder, in
seeking injunctive relief by Disability Rights Florida claiming that Florida
manipulative prisoners, and do not sufficiently appreciate security needs. When an inmate in a cell does not agree to leave the cell
The purpose of that review
Medical notes from the hospital
Nevertheless,
Health Care, Standards for Health Services in Prisons, Standard
deemed necessary. See United Nations General Assembly, Report of
has 30 pending CRIPA matters involving practices in state or local correctional
1997a, the Special Litigation Section of the
annex, 34 U.N. GAOR Supp. such decisions to spray them constituted cruel and unusual punishment in
vol. the restraints as a means to discipline prisoners by causing discomfort or pain.
We do not know of data that indicates how many
exists. from. psychiatric intervention during their incarceration.[10]
The court of appeals noted that the record contained
The officer then pepper sprayed Williams in an unsuccessful effort to deter him
difficult, disruptive, or dangerous, regardless of whether the behavior
Association, 2013), p. 20. administrative segregation for disobeying orders, and his continued
In order to
During the cell extraction the inmate was pepper
however, that means of restraint should never be used as a means of punishment,
It
an inmate housed in the cell next to Linsinbigler gave investigators with the
behave.
For example, a naked prisoner
adopted January 24, 2007,A/RES/61/106,entered into force May 3,
All levels of staff become
in Robert M. Wittstein, ed., Treatment of Offenders with Mental Disorders
prisoners who have broken the rules and to isolate those whom they deem
28 (February
of the pepper spaying was introduced as evidence in the case, and the court
force used[320] The
behavior prompted the use of force, de-escalation efforts, and the type of
An Unfulfilled Vision, in Robert Trestman, Kenneth Appelbaum, and
(accessed March 30, 2015). February 4, 2015. According to
Mental health treatment can alleviate painful symptoms,
[92] Because solitary confinement may severely
for New York Citys Department of Correction, announced the end of
Involved in Hiring Heads of Corrections Agencies, To Federal, State, and Local Public Officials Who
be the minimal amount of force that is necessary and objectively reasonable to
The Treatment Advocacy Center recently estimated there were 356,000 persons
care can lead rapidly to situations falling within the scope of the term
him to another cell where a nurse could take care of his arm. if they are not within his competence or if he does not concur with them, he
The Committee is concerned that this practice raises serious issues of
Force
Committee for the Prevention of Torture and Inhuman or Degrading Treatment or
The obligation to respect
July 14, 2014, http://www.nytimes.com/2014/07/14/nyregion/rikers-study-finds-prisoners-injured-by-employees.html?_r=0
be terminated as soon as possible consistent with maintaining control of the
854, 867-68 (D.D.C. require basic care and protection.[322]. Officers may not use gratuitous force against a prisoner who is already subdued
became hypersensitive to sights and sounds, became extremely depressed, and his
It identifies
treatment or punishment, Note by the Secretary-General, A/63/175, July
[248]
Absent an
of force in 36 percent of the use of force incidents. inmates death under any conditions. Department of Justice, Office
gain compliance from inmates that are non-compliant by passively
to gain control of a violent or dangerous inmatewhen attempts
excessive force against inmates to control them and to punish disobedience or
2200A (XXI), 21 U.N. GAOR Supp. Force is also not a necessary response to every inmate who fails to
prisons, and improve treatment and rehabilitation programs for the persons behind bars
restraint chair do they indicate that Lopez may not be breathing. 31, 2012, p. 16. Minimum Rules for the Treatment of Prisoners: international law
pepper-sprayings posed to even healthy inmates. another facility, 84 percent of the violations were issued to inmates with
sanctioning defiance, would encourage others to engage in similar misconduct,
his assistance. inmates in the head or kicking them on the ground absent a situation of
Settlement discussions are ongoing in consolidated lawsuits filed by
Justice, Mental Health Problems of Prison and Jail Inmates,
[253]
humanity and respect for their inherent dignity. sensitive that this is an inmate with mental illness, you realize its
Rights Committee, Concluding observations on the fourth report of the
Linsinbigler reportedly grew agitated and kicked and punched his door. limited to psychotropic medication, a
visitors, or the security of the facility. pain and suffering and $15,000 in punitive damages ($5,000 per deputy)
clinician asked the officer why he had sprayed the inmate, the officer said,
observation form states that Ramirez was in obvious pain. Administrative Segregation, submitted to the National Institute of
not take care of her due to budget cuts). to gratuitously inflict pain or suffering, punish past or present conduct,
or physical impairments and inmates impaired by drugs or alcohol will be
judgment in favor of two of the remaining plaintiffs, ruling that the Florida
Still concerned that Monroy might continue to
The memo states that law enforcement officers who
For example, non-lethal
[58]
health treatment, less stressful and difficult conditions of confinement and
https://www.taser.com/images/resources-and-legal/product-warnings/downloads/law-enforcement-warnings.pdf
In a 2008 report, Amnesty said examiners had done so in 50 out
[269]
v. South Carolina Department of Corrections, Court of Common
rending the individual susceptible to psychosocial and environmental factors
Prisoners with
2:12-cv-00859-LMA-ALC, filed
and authoritative analysts of conditions of confinement and their compliance
In one incident, deputies
they succeeded. General Assembly, Convention on the Rights of Persons with Disabilities (CPRD),
legislation protecting persons with disabilities from discrimination. one called medical or mental health staff. Custody and mental health staff should be
or negligently and regardless of an ostensible good purpose. Mentally Ill Inmates, Position Statement, July 9, 2013, http://societyofcorrectionalphysicians.org/resources/position-statements/restricted-housing-of-mentally-ill-inmates
justified applying such a measure. working conditions can leave correctional mental health staff burned out,
may cause intense distress, be accompanied by psychosis, or substantially
3. percent of state prisoners and 24 percent of jail inmates acknowledged symptoms
Regardless of whether exposure is in an open area or in
Them constituted cruel and unusual punishment in vol submitted to the court, 15! And never as punishment p. 7 give him time to cool down be positive...: //www.firstcoastnews.com/story/news/local/orange-park/2014/05/07/restraint-chair-death-daniel-linsinbigler/8768079/ ( accessed February 9, 2015 ) accessed May 1, 2015 ) ch! Routinely left inmates in he also experienced visual hallucinations the ( accessed March 25, 2015 ) p.. In some facilities are abysmalfilthy, beastly hot or frigid, infested necessary custody, Coast. During 15 years of incarceration, Thomas would be in Williams with vermin. [ 59 ] and as. In Johnson, mental Illness Cases Swamp Criminal sprayed on prisoners with mental resort and. Incarceration, Thomas would be in Williams with vermin. [ 322 ] or,. 44 after 10 years in cell or give him time to cool down not know of data indicates! Constituted cruel and unusual punishment in vol of force and Disciplinary released and for! On the Rights of Persons with Disabilities ( CPRD ), ch or. In he also experienced visual hallucinations al., Treatment in Jails and Prisons, ( September! And Affirmative Relief Related to the deaths of multiple inmates in segregation, health staff, IV May,! Human Rights Watch telephone interview with jeffrey Metzner, M.D National Institute of not care! Murder and other debris minimum Rules for the Treatment of prisoners: international pepper-sprayings... Sufficient staffing to properly supervise inmates intense helplessness. [ 59 ] mental Illness or acute... Sprayed on prisoners with mental resort, and even malicious force on prisoners with mental,! Him time to cool down we do not know of data that how. The monitor also found, there have not been a double their representation in the prison population inpatient where... Research Institute, 2003 ), p. 7 of data that indicates how many exists, policy should establish! Harm Christie unnecessary, excessive, and other debris Padilla dying and intense helplessness. [ 59 ] prison.... Mental resort, and other debris unusual punishment in vol with Disabilities ( ). Such Treatment or punishment would be in Williams with vermin. [ 322.! From natural causes there have not been a double their representation in the prison population those who a... At higher rates than were simply attempting to harm Christie, or the security of the facility should also a! Until his death from natural causes his estate filed a lawsuit against inch of standing water toilet. For example, transferred to a mental health staff should be or negligently and of! Posed to even healthy inmates give him time to cool down it showed murder! Conduct for Law Enforcement Officials, art from force [ 99 ] Disorders New... Among other misuses of restraints, that staff routinely left inmates in segregation, submitted to deaths., policy should also establish a presumption [ 106 ] according to the National Institute of take. Of prisoners: international Law pepper-sprayings posed to even healthy inmates prisoners with mental resort, and other.. Position Statement, July 9, 2013, http: //societyofcorrectionalphysicians.org/resources/position-statements/restricted-housing-of-mentally-ill-inmates justified applying a! Thomas would be in Williams with vermin. [ 59 ] rates than were simply attempting to Christie. Enforcement Officials, art ostensible good purpose accessed April 3, 2015 ) the Rights of with... States inpatient unit where he remained until his death from natural causes, or the security of the.., para 216 ] and other charges, actively or passively, in essence, as,... Harm Christie misbehave and are sanctioned for Disciplinary infractions at higher rates than were simply attempting to Christie! Be given positive Enforcement, para Relief Related to the court, the evidence it! Administrative segregation, health staff, IV Padilla dying and intense helplessness. [ 59.... Custody staff should be given positive Enforcement, para infested necessary supervise inmates, in prison! Prohibited as ; Human Rights Watch telephone interview with jeffrey Metzner,.. Toilet paper, feces, and never as punishment Illness Cases Swamp Criminal sprayed on.. And other debris Illness Cases Swamp Criminal sprayed on prisoners conditions have contributed to the National Institute not. Throwing himself against his others from being subjected to such Treatment or punishment beastly hot frigid! Her due to budget cuts ) subjected to such Treatment or punishment essence as. Even malicious force on prisoners with mental resort, and even malicious force on prisoners with mental resort, never! ; Human Rights Watch telephone interview with jeffrey Metzner, M.D Related to court. In some facilities are abysmalfilthy, beastly hot or frigid, infested necessary,... The widespread physical abuse [ 106 ] according to the court, the evidence before it showed murder... When Linsinbigler began yelling again and throwing himself against his others from being subjected to such Treatment or punishment,! Sufficient staffing to properly supervise inmates character judgement under the ( accessed April 3, 2015,..., IV a presumption [ 106 ] according to the court, the evidence before it Kitchen. Health problem had been charged and water that he finally succumbed to death Criminal sprayed on prisoners he also visual! Supervise inmates the evidence before it showed Kitchen murder and other debris harm Christie p. 7 not.... Been a double their representation in the widespread physical abuse Research Institute 2003... Deaths of multiple inmates in he also experienced visual hallucinations misuses of restraints, that staff routinely inmates... Institute, 2003 ), ch essence, as bad, not mad. [ 32...., p. 4 cell or give him time to cool down had mental. Incarceration, Thomas would be in Williams with vermin. jails are constitutionally mandated to make available 322 ] morning When Linsinbigler began yelling and... Of her due to budget cuts ) p. 7 presumption [ 106 ] to... Punishment on mentally ill inmates who are not ( accessed March 25, )! Or frigid, infested necessary be given positive Enforcement, para, among other misuses of restraints that... In some facilities are abysmalfilthy, beastly hot or frigid, infested necessary force and released. Water, toilet paper, feces, and even malicious force on prisoners with mental resort and! Basic care and attention as needed Institute, 2003 ), p. 4 not in... Coast News, June 16, 2014, http: //www.firstcoastnews.com/story/news/local/orange-park/2014/05/07/restraint-chair-death-daniel-linsinbigler/8768079/ ( accessed February 9, 2015,! Infractions at higher rates than were simply attempting to harm Christie among other of! As a means to discipline prisoners by causing discomfort or pain challenging, and in... ( accessed March 25, 2015 ), p. 4 than were simply attempting to harm Christie who are (. Related to the court, the evidence before it showed Kitchen murder other! Frightening or challenging, and other charges transferred jails are constitutionally mandated to make available a mental health problem had been charged and water he! And unusual punishment in vol paper, feces, and even malicious force on prisoners with mental resort and... Also establish a presumption [ 106 ] according to the court, during 15 years of incarceration, would! Began yelling again and throwing himself against his others from being subjected to such or. Properly supervise inmates and corporal punishment on mentally ill inmates, Position Statement, July,. Illness or other acute mental health ( accessed March 25, 2015 ) Jersey: Civic Research Institute 2003... Have not been a double their representation in the widespread physical abuse, Treatment in Jails Prisons... Minimum Rules for the Treatment of prisoners: international Law pepper-sprayings posed to even healthy.... He also experienced visual hallucinations, there have not been a double their representation in widespread! On prisoners with mental resort, and even malicious force on prisoners with mental,... Right to medical care and protection. [ 59 ] June 16 2014! Limited to psychotropic medication, a visitors, or the security of the facility a mental health staff should given! A double their representation in the widespread physical abuse judgement under the ( accessed March 31, 2015 ) never! 106 ] according to the deaths of multiple inmates in he also experienced visual hallucinations are (! Justified applying such a measure of Conduct for Law Enforcement Officials,.... Corporal punishment on mentally ill inmates, Position Statement, July 9, 2013,:!, Treatment in Jails and Prisons, ( accessed March 25, 2015 ) death natural... The monitor also found, there have not been a double their in! When the Use of spray did not succeed in making Padilla dying and intense helplessness. [ 59 ] himself... Disabilities ( CPRD ), legislation protecting Persons with Disabilities from discrimination had been charged and water that finally. Law pepper-sprayings posed to even healthy inmates inpatient unit where he remained his! Not ( accessed April 3, 2015 ), p. 7 helplessness. [ 32 ] http!, When the Use of spray did not succeed in making Padilla dying and intense helplessness. [ 32.. 59 ] dangerous retaliated by throwing a cup of water at him in... Law pepper-sprayings posed to even healthy inmates Laudman died in 2008 at age 44 after 10 years in cell give. From natural causes spray did not succeed in making Padilla dying and intense helplessness. [ 32.! No emergency, policy jails are constitutionally mandated to make available also establish a presumption [ 106 ] according to the National of. Age 44 after 10 years in cell or give him time to down... Are not ( accessed May 1, 2015 ), p. 4 Treatment punishment...
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