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"A New Asylum: Examining The Insanity Of Solitary Confinement For Mentally Ill Inmates" by Benjamin Pomerance

A New Asylum: Examining The Insanity Of Solitary Confinement For Mentally Ill Inmates

by Benjamin Pomerance

"[I]f a prison system has gone bad or is bad . . . in its provision of mental health care, what you have to do is go to the segregation units and you will find the sickest people locked down, unattended to, and it's the way that a malfunctioning prison system operates to hide their mentally ill . . ."

-- Expert testimony of Dr. Fred Cohen in the prisoners' rights case Austin v. Wilkinson, September 2001

In November 2001, 17-year-old Jesse McCann wrapped a bed sheet around his neck, tied several tight knots, and jumped off his cot into space. See CORR. ASS'N OF N.Y., LOCKDOWN NEW YORK: DISCIPLINARY CONFINEMENT IN NEW YORK STATE PRISONS 6 (2003). Within moments, he was dead. Officers at New York State's Downstate Correctional Facility, where McCann was incarcerated, found him hanging in his cell. The suicide, as his uncle later told a newspaper reporter, was likely attributable to McCann's fear and confusion after being ordered to "disciplinary lockdown", an isolation-based punishment that is the functional equivalent of what is popularly labeled "solitary confinement." See Mary Beth Pfeiffer, Groups Fault Prison Care of the Mentally Ill, POUGHKEEPSIE JOURNAL, Oct. 25, 2003; see, e.g., Jamie Fellner, A Corrections Quandary: Mental Illness and Prison Rules, 41 HARV. C.R.-C.L. L. REV. 391, 402 (2006).

Lockdown at Downstate Correctional, like forms of administrative segregation employed at prisons throughout the United States, existed almost exclusively for one purpose: to penalize inmates for violations of facility regulations. See, e.g., HUMAN RIGHTS WATCH, MENTALLY ILL PRISONERS AND SEGREGATION 1 (2003). Yet unlike certain other prisoners at Downstate, the infractions that led to McCann's placement in "the box" may well have been due to forces beyond his control. A state Commission of Correction investigation revealed that McCann suffered from clinical depression, and often struggled with anxiety attacks--mental illnesses which quite probably were the cause of his rule violations. See Pfeiffer, supra. Secluded in his lockdown cell for 23 hours a day, his anxiety attacks had only increased until his final desperate act. See id.

For decades, even centuries, reports have pointed to the toll that prison life takes on an inmate's mental state. See, e.g., Fellner, supra, at 391. With prisoners who, like McCann, already suffer from mental health impairments, the detrimental impact of prison time often magnifies significantly, particularly due to a lack of access to proper mental health services for inmates. See HUMAN RIGHTS WATCH, supra, at 6. Yet perhaps no single element of incarceration can damage a mentally ill inmate as much as confinement within a prison's "segregation unit"-- a practice which was recently denounced by a United Nations Special Rapporteur as a form of torture. Press Release, United Nations Human Rights Committee, Office of the High Commissioner, UN Special Rapporteur on Torture calls for the Prohibition of Solitary Confinement (Oct. 18, 2011).

This article looks at the damage caused by this practice, and concludes that despite recent measures to finally address this problem, the only rightful and humane solution is to ban the use of solitary confinement for mentally ill prisoners entirely. Part One of this article looks at some of the most harmful and common psychological impacts of forcing mentally ill prisoners into segregated housing units. Part Two briefly studies the need for a law which eliminates this solitary confinement for the mentally ill entirely, as well as the rationale behind political opposition for such a measure. Part Three focuses on the important achievements for mentally ill prisoners achieved through the passage of New York State's "SHU Exclusion Law". Part Four looks at the shortcomings of this law, and reveals why, despite these improvements, this law still does not go far enough toward protecting mentally ill prisoners. Finally, Part Five describes why a complete ban on solitary confinement for the mentally ill is the only way to adequately protect mentally ill inmates from the inhumane effects of isolation punishment on their lives.

I Causes And Effects: The Detrimental And Dangerous Psychological Impacts Of Solitary Confinement On Mentally Ill Prisoners

Given that prisoners with absolutely no history of mental illness often experience symptoms like extreme despair, rage, claustrophobia, hallucinations, and memory loss as a result of their experience in segregation, one can only imagine how detrimental a stint in solitary confinement can be for an individual with a pre-existing mental condition. Fellner, supra, at 403. Numerous studies have shown that mental illnesses -- from major depression to bipolar disease to schizophrenia -- worsen significantly in these isolated environments. See, e.g., Fellner, supra, at 403-404 (citing several of the leading studies in this area).

Prisoners with anxiety disorders can experience "a psychologically crippling panic reaction" when forced into such a solitary lifestyle, and inmates "prone to suicide ideation and attempts will become more suicidal in that setting." HUMAN RIGHTS WATCH, supra, at 5 (quoting findings by Professor Hans Toch and Dr. Terry Kupers). As one federal judge put it, solitary confinement of the mentally ill "is the mental equivalent of putting an asthmatic in a place with little air to breathe." Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995).

Nevertheless, it is the mentally ill inmates of America's prisons who tend to be the most frequent guests of segregation units, despite the fact that they are more poorly suited for isolated confinement than perhaps any other demographic group. See CORR. ASS'N OF N.Y., supra, at 1; see also HUMAN RIGHTS WATCH, supra, at 6. With approximately 24% of the total national inmate population suffering from some sort of serious mental illness, American prisons may hold more mentally ill individuals than the nation's psychiatric hospitals. See The High Costs of Cutting Mental Health--Criminal Justice, NAT'L ALLIANCE ON MENTAL ILLNESS (2010); HUMAN RIGHTS WATCH, supra (stating that America's prisons, as of 2003, held three times as many mentally ill individuals as the nation's psychiatric hospitals).

With prisons generally reluctant to use an inmate's mental illness as a mitigating factor in handing down punishments for facility rules violations, despite the fact that a mentally ill prisoner might not even have the capacity to comprehend the regulation that he or she is breaking, these mentally ill inmates naturally are at a higher risk of breaching some rule and ending up in "the box." See Fellner, supra, at 398 (noting that many officials fear that inmates could "fake" mental illness). As a consequence, states have reported that the mentally ill typically constitute between one-quarter and one-half of their total segregated unit population. See generally HUMAN RIGHTS WATCH, supra.

When a mentally ill inmate's psychological condition begins to worsen in solitary confinement, the needs of these prisoners are too often ignored, as was the case with Jessie McCann and with so many other similarly tragic examples. Prisoners who request to speak with mental health staff often wait long periods of time before someone turns up to work with them, directly contradicting the accepted scientific principles about the need for consistent active treatment and care for patients with mental illnesses. HUMAN RIGHTS WATCH, supra, at 7.

Sometimes, if an inmate's behavior is "self-detrimental" enough, he or she will be sent to an in-patient facility for "help". See Fellner, supra, at 404. However, once the prisoner's condition is "stabilized," he or she is usually sent back to solitary confinement, and the problems begin all over again. See id.

II Ignoring The Need: Why American Lawmakers Have Neglected To Prohibit This Harmful And Dangerous Practice

In spite of this vicious cycle for mentally ill inmates, the federal government and state governments have continually opposed the notion of outlawing solitary confinement for prisoners with mental disabilities. See, e.g., Editorial, Prison Horrors for the Mentally Ill, N.Y. TIMES, Apr. 23, 2007. Although certain politicians have taken an outspoken stand against confining mentally ill inmates in these isolated settings, the general tenor of these discussions has been largely antagonistic toward this concept. See, e.g., HUMAN RIGHTS WATCH, supra, at 13-15.

Despite the fact that the United States Supreme Court has held that prisoners have a Fourteenth Amendment liberty interest in not being placed in a segregated unit, and that prison officials violate the Eighth Amendment prohibition against cruel and unusual punishment if they know "that inmates face a substantial risk of serious harm" and fail to take "reasonable measures to abate it", state and federal politicians have continually refused to outlaw this practice that is well-known to cause harm to mentally ill prisoners. See Wilkinson v. Austin, 545 U.S. 209, 223-24 (2005); Farmer v. Brennan, 511 U.S. 825, 847 (1994).

The fact that such inhumane treatment of the mentally ill behind prison walls has been allowed to continue in such a manner violates the most basic principles of what our criminal justice system is supposed to stand for. While passing legislation that eliminates solitary confinement for the mentally ill will likely be unpopular among voters who want "tough on crime" leaders, it is a measure which must be enacted. Without it, America cannot truly be said to be a nation which rejects the use of excessive and unreasonable measures to attain penological goals.

Thankfully, although no measure banning the use of solitary confinement for mentally ill prisoners has ever been passed, several states -- from California to Florida to Texas -- have in recent years instituted measures (some of them ordered by court decisions) aimed at limiting the extent to which isolation is used as a punishment for mentally ill prisoners. See HUMAN RIGHTS WATCH, supra, at 13-15. While it is impossible to address all of these reforms here, we will look briefly at the creation and impact of one state's latest attempt to deal with this problem: the "SHU Exclusion Law" in New York State.

III Moving Toward A Solution: A Look At Recent Legislative Developments Toward Helping Mentally Ill Prisoners In New York State

The movement that ultimately led to this law in New York began in 2001, when a reporter for the Poughkeepsie Journal wrote a series of investigative pieces about poor treatment of mentally ill inmates within the state's isolation-based "secure housing units" (SHUs). See generally Pfeiffer, supra.

One year later, the Albany-based organization Disability Advocates, Inc. filed a federal lawsuit alleging Eighth Amendment violations on the grounds that mentally ill inmates in New York were receiving woefully inadequate treatment for their disabilities, thereby increasing their likelihood committing institutional violations that led to punishment by the clearly harmful means of solitary confinement. See Disability Advocates, Inc. v. New York State Office of Mental Health, No. 02-CV-4002 (S.D.N.Y. 2002). The year after that, the Correctional Association of New York released a report on the state's SHUs which substantiated many of the lawsuit's claims. See generally CORR. ASS'N OF N.Y., supra. Astoundingly, the report noted that while New York's SHUs housed about 10% of the state's prisoners, the isolation units accounted for nearly 50% of its in-prison suicides, most of which were committed by inmates diagnosed with severe mental illnesses. CORR. ASS'N OF N.Y., supra, at 1 (emphasis added).

The Correctional Association's report spurred New York State Assemblyman Jeffrion Aubry, Chair of the Assembly's Committee on Corrections, to hold hearings about the issue of whether SHU was an appropriate punishment for mentally ill inmates. By 2004, Aubry had introduced legislation forbidding assignment of mentally ill prisoners to SHUs, a bill which ultimately passed both houses of the Legislature and even earned an endorsement from the state's Correctional Officers Union. See James Ridgeway, Locking Down the Mentally Ill, THE CRIME REPORT, Feb. 18, 2010, http://www.thecrimereport.org/archive/locking-down-the-mentally-ill. Yet in 2006, under pressure from New York State Department of Correctional Services leaders, then-Governor George Pataki vetoed the bill, stating that its passage would prohibit prisons from punishing inmates who refused to adhere to "the most minimum levels of civilized behavior." See id.

A year later, however, Disability Advocates negotiated a settlement in their lawsuit against the State, agreeing to terms which demanded substantial improvements in mental health care for prisoners and significant limitations in the use of SHU as a punishment for the mentally ill. See Sarah Kershaw, New Rules for Confining the Mentally Ill, N.Y. TIMES, Apr. 25, 2011. Virtually all of these terms were ultimately codified in the state's "SHU Exclusion Law," enacted by the Legislature in January 2008 and became effective on July 1, 2011. See "SHU Exclusion Law", Codified as N.Y. CORRECT. LAW §§ 137 (McKinney 2003 & Supp. 2011), 401-a (McKinney 2008 & Supp. 2011).

The law requires more thorough mental health screenings when prisoners initially enter state custody and demands that the State provide out-of-cell active treatment and programming to all SHU inmates who suffer from "serious mental illnesses." N.Y. CORRECT. LAW §§ 137 (6)(d)(ii)(A); N.Y. CORRECT. LAW §§ 137 (6)(d)(iii). Most importantly, it requires that prisoners with serious mental illness be "diverted or removed" from SHU to a Residential Mental Health Treatment Unit if their SHU confinement could last for longer than 30 days. N.Y. CORRECT. LAW §§ 137 (6)(d)(i). The law's lone exception exists if removal to a residential unit would pose a "substantial threat" to the facility's security or if the assessing clinician "determines that placement in segregated confinement is in the prisoner's best interest based on his/her mental condition." N.Y. CORRECT. LAW §§ 137 (6)(d)(ii)(E).

Clearly, this law represents a considerable improvement for the treatment of mentally ill inmates in New York. The new Residential Mental Health Unit at Marcy Correctional Facility, with more than 100 beds and at least four hours of out-of-cell programming per day for each inmate, is a significant example about how conditions have improved for these prisoners. See Mary Esch, N.Y. Prison System Opens Unit for Mentally Ill, ASSOCIATED PRESS, Dec. 15, 2009. Opened in December 2009, the unit is available for inmates who receive a disciplinary violation with a penalty of more than 30 days in segregated housing and who have been diagnosed with "a serious mental illness." See Allison Roselle, DOCS Opens New Facility for Mentally Ill Inmates, LEGISLATIVE GAZETTE, Jan. 4, 2010, available at http://www.legislativegazette.com/Articles-c-2010-01-04-64546.113122_DOCS_opens_new_facility_for_mentally_ill_inmates.html. Without a doubt, this is far better than the 23-hours-per-day confinement that these mentally ill inmates would otherwise receive. From the start, the unit has been recognized as "the most comprehensive and complex mental health prison treatment program developed by the United States in the past 20 years." NEW YORK STATE OFFICE OF MENTAL HEALTH, DOCS, OMH, OPEN RESIDENTIAL MENTAL HEALTH UNIT AT MARCY CORRECTIONAL FACILITY (Dec. 23, 2009).

In addition, the Department of Correctional Services (which exists today as the New York State Department of Corrections and Community Supervision) has taken further steps to protect mentally ill prisoners who receive disciplinary violations. A Residential Mental Health Unit comparable to the Marcy unit now exists for mentally ill female inmates at Bedford Hills Correctional Facility. See Roselle, supra. Similar units for mentally ill inmates penalized for breaking institutional rules were opened on July 1, 2011, at Five Points Correctional Facility and for Attica Correctional Facility. See id. Although these units are not yet fully operational, plans are underway to make these units fully functioning within the very near future.

IV Why The Problems Continue: The Shortcomings Of A Law That Is Progressive, But Not Progressive Enough

The measures taken at New York State correctional facilities, well-intentioned though they may be, still are not enough to properly deal with this problem. Furthermore, New York's SHU Exclusion Law -- while one of the nation's most progressive statutory safeguards in this area -- is not enough. Ultimately, this is the equivalent of trying to heal a gaping wound with a tiny bandage, for while it is a helpful step in the right direction, it falls painfully short of being a cure.

Care of mentally ill inmates remains a significant problem in New York State's prison system today, as evinced by the eleven mentally ill inmates who committed suicide in New York correctional institutions in 2010, a number which reflects more than half of the total number of prisons suicides in the state. See, e.g., NEW YORK STATE ASSEMBLY STANDING COMMITTEE ON CORRECTION, NOTICE OF PUBLIC HEARING (Dec. 6, 2011) (stating that in 2010, 20 inmates committed suicide in New York State prisons, 11 of whom were already diagnosed with a mental illness). Oversight of the treatment of mentally ill inmates continues to be recognized as deficient in certain areas, despite the fact that the SHU Exclusion law charges the New York State Commission on Quality of Care and Advocacy for Persons with Disabilities with the task of monitoring compliance of this statute. See id.; see also Prison Suicides Doubled in 2010 (YNN television broadcast Dec. 6, 2011) (citing a general lack of oversight of prison treatment of mentally ill inmates as a cause for the increase in suicides).

Perhaps most troubling of all, though, is the fact that certain key state agencies responsible for implementing this law do not seem to hold it in particularly high regard. For instance, at a December 2011 public hearing about mental health treatment in prison, the Department of Corrections, the Office of Mental Health, and two other state agencies failed to send any representatives to answer questions, despite being invited to do so. See N.Y. COMM. ON CORRECTION, 2011 ANNUAL REPORT 11 (2011). Such apathy by the part of these state agencies produces doubts about whether these new legal standards really are being taken seriously.

The fundamental concern with the SHU Exclusion Law, and with any other law of this nature, is that it does not solve the problem that it sets out to address. Instead, it provides too many exceptions under which prisons can treat mentally ill inmates in an inhumane manner. Under this law, prisoners with mental illnesses that are not classified as "serious" are not protected from SHU confinement, even though experts have consistently held that solitary isolation can be damaging for an inmate with any mental illness. See Part I, supra.

Additionally, the Department of Corrections can still easily justify sending mentally ill inmates to segregated housing on "substantial threat" or "best interest" grounds. See N.Y. CORRECT. LAW §§ 137 (6)(d)(i). As commentators have noted, these terms are not explicitly defined within the law, leaving too much discretion in the hands of prison officials to decide when, for instance, an inmate truly poses a "substantial threat" to the prison population. See, e.g., TESTIMONY BY JACK BECK, DIRECTOR, PRISON VISITING PROJECT, CORR. ASS'N OF N.Y. (Mar. 17, 2009). Thus, even though the law specifically provides for oversight of treatment of mentally ill inmates, including decisions to send a mentally ill inmate to SHU, the power to make these decisions still ultimately rests in the hands of prison officials, who can use the loosely defined terms of the statute to prove that they had a "legitimate" reason for assigning a mentally ill inmate to "the box."

Given that expert evaluators have recognized that "mental health care in prison is not uniform across (New York's) system," this degree of discretion afforded to prisons in this area is particularly problematic. See SUICIDES IN NYS PRISONS REACH HIGHEST RATE IN 28 YEARS, CORR. ASS'N OF N.Y. (Dec. 5, 2011). Conceivably, five prisons could hold five different definitions of what constitutes a "substantial threat" to the facility's security or to the safety of other inmates. In fact, a prison could potentially even determine that inmates suffering from certain categories of mental illnesses are, by the very nature of the disease, substantial threats to other inmates and to the facility as a whole.

Given the legislative history of this statute, as well as the language of the law itself, this does not appear to be what the drafters of the SHU Inclusion Law intended to happen. Yet given the lack of understanding that many prison officials possess about the people with mental illnesses, along with the still-too-wide degree of discretion afforded to these officials by the SHU Exclusion Law, this continued disregard for the hazards of putting mentally ill prisoners in segregated housing units could easily result.

The dilemma created by this law, as some experts have already noticed, is that too much authority is vested in a party that is unlikely to safeguard the statute's primary interests. The paramount goal of any correctional system is security and discipline, while the main objective of any treatment system is care and quality of life. See Cara Matthews, Advocates, Assembly Urge Improvements in NYS Prison MH Care, GARNETT ALBANY BUREAU, Dec. 6, 2011, available at http://www.nyaprs.org/e-news-bulletins/2011/2011-12-07-GNS.cfm (quoting comments made by Jack Beck, Director of the Correctional Association of New York's Prison Visiting Project). When the two issues are thrown together in one setting, as they are in matters of prison healthcare, the result is an "inherent conflict" between these two sets of aspirations. See id. By giving the final decision-making power to the correctional system, as the SHU Exclusion Law does, the treatment system's goals will almost certainly suffer as a result. See id. This is true even if oversight of the correctional system's decision-making is assigned to a treatment system entity, as is the situation in New York.

Overall, the SHU Exclusion Law sets up a situation where the fox is in charge of guarding the chicken coop. And while conditions for mentally ill inmates are certainly better under this law than they were without it, drawbacks still remain, caused by this law's over-reliance on correctional facility officials to "police" themselves. At least one recent report has noted that certain New York State "facilities are still sending prisoners with serious mental illness to disciplinary solitary confinement," despite the fact that the SHU Exclusion Law explicitly prohibits this type of punishment for the mentally ill. See id. With prison monitoring just one of many demands on the time and resources of the Commission on Quality of Care and Advocacy for Persons with Disabilities, the state body required to oversee any assignment of mentally ill prisoners to SHU, it is not at all surprising that some of these situations slip by unnoticed. Yet it is very troubling to realize that under the current legal structure in New York State, one of the most advanced of all states in protecting mentally ill prisoners from solitary confinement, this harmful practice still continues to take place.

V A Call To Change: Recommendations For Revising New York State's SHU Exclusion Law To Fully Exclude Mentally Ill Inmates From SHU

There is little question that although the SHU Exclusion Law provides important safeguards for mentally ill prisoners, additional improvements are necessary. At the very least, the New York State Legislature should revise the SHU Exclusion Law so that the evaluation of whether a mentally ill inmate poses a danger to other inmates or to facility security is performed by a neutral, third-party entity. This should be a small committee that is composed of both mental health professionals (who do not currently work as mental health professionals in the New York prison system) and corrections officials, ensuring that both the care perspective and the corrections perspective are represented in discussions of whether to assign a mentally ill inmate to SHU.

Furthermore, the scope of the law should be expanded to protect not only inmates with "serious" mental illnesses, but all mentally ill inmates. This is essential, as practically every mentally ill inmate is put at risk by assignment into isolated confinement for 23 hours per day. The present law, as discussed above, leaves far too many mentally ill inmates unprotected simply because their medical condition is not deemed to be "serious enough."

Yet there is a better solution, one that would heal the wound rather than merely trying to stop the bleeding. That solution is the one for which this article has advocated since the outset: banning the practice of disciplinary assignment to SHU for mentally ill inmates entirely. Mental health professionals have recognized that even with better segregated housing facilities in New York prisons, the mentally ill still should not be in there at all. The risk to their well-being is too great to justify imposing these harsh conditions on them for the sake of teaching them a lesson about institutional authority. Forcing mentally ill prisoners into an environment which can -- and too often does -- lead to exacerbation of their health condition, to self-harm, and even to suicide is not, on balance, validated because that particular inmate broke an institutional rule.

There is no doubt that correctional officials in New York would strongly oppose such a measure, just as they did the last time such legislation was proposed. See Part III, supra (noting that legislation that would have banned use of SHU as punishment for mentally ill prisoners would likely have been passed previously in New York State, were it not for opposition of the Department of Correctional Services). Quite likely, they would argue that completely prohibiting the use of SHU as a punishment for mentally ill prisoners would strip prison leaders of the necessary autonomy to take measures to safeguard institutional security. Ordinarily, such an argument would have merit, as prison officials do need to possess the authority to meet penological goals.

Yet solitary confinement of the mentally ill, as explained in this article, goes beyond penological goals. Banning this practice would not strip prisons of the authority to penalize wrongdoers. Indeed, punishments other than SHU, penalties that clearly take the inmate's mental health condition into full account, can still be handed down at disciplinary hearings. Instead, prohibiting solitary confinement to penalize mentally ill prisoners would finally bring a long-overdue end to a harmful and barbaric practice which runs contrary to our values against cruel and unusual punishment.

Given the rise of popular sentiment toward its abolition, it will likely take one state to end solitary confinement of the mentally ill before several others follow. There is no reason why New York should not be the first to take this essential step.

Conclusion And Final Thoughts

New York State's SHU Exclusion Law is, without a doubt, a vital "step toward basic human decency." See Editorial, supra. It is a measure which signals significant progress toward more humane treatment of inmates who suffer from mental illnesses, progress which is not only important, but absolutely necessary.

However, this law should not be the ending point -- not for New York and not for any state that passes similar legislation. Instead, given the life-threatening severity of the impact of solitary confinement on this class of inmates, advocates should not rest until laws banning assignment of mentally ill prisoners to segregated housing units are passed and implemented nationwide. See, e.g., AMERICAN BAR ASS'N, STANDARDS ON TREATMENT OF PRISONERS, Standard 23-2.8 (Feb. 2010). As the suicide of Jesse McCann and the cases of so many other mentally ill prisoners illustrate, the consequences of sending mentally ill inmates to solitary confinement are too tragic and permanent to overlook any longer.

Today, in an era where three times as many mentally ill individuals are in American prisons than in the nation's hospitals, the need to end solitary confinement for the mentally ill is greater than ever. See Rita Rubin, Mentally Ill People are Sent to Jail More Often Than Hospital, USA TODAY, May 13, 2010 (citing a study performed by Dr. E. Fuller Torrey and Dr. James Pavle on this subject). Thus, it is time to prevent the segregated housing units of American prisons from becoming our newest variety of asylum for the mentally ill. It is time to recognize punishing mentally ill prisoners by assignment to solitary confinement as what it really is: a form of cruel and unusual punishment which is, in the truest sense of the word, insane.

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This page contains a single entry from the blog posted on February 17, 2013 5:13 PM.

The previous post in this blog was "Due Process, Human Rights, And International Dispute Settlement: Schuler-Zgraggen v. Switzerland (1993)" by Briana West.

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