|Criminology and penology|
Solitary confinement is a form of imprisonment in which the inmate lives in a single cell with little or no meaningful contact with other people. A prison may enforce stricter measures to control contraband on a solitary prisoner and use additional security equipment in comparison to the general population. Solitary confinement is a punitive tool within the prison system to discipline or separate disruptive prison inmates who are security risks to other inmates, the prison staff, or the prison itself.However, solitary confinement is also used to protect inmates whose safety is threatened by other inmates by separating them from the general population.
In a 2017 review, "a robust scientific literature has established the negative psychological effects of solitary confinement", leading to "an emerging consensus among correctional as well as professional, mental health, legal, and human rights organizations to drastically limit the use of solitary confinement."The United Nations General Assembly Standard Minimum Rules for the Treatment of Prisoners were revised in 2015 to extend restrictions on solitary confinement exceeding 15 days.
The practice of solitary confinement in the United States traces its origins back to the 19th century when Quakers in Pennsylvania used this method as a substitution for public punishments. Research surrounding the possible psychological and physiological effects of solitary confinement dates back to the 1830s. When the new prison discipline of separate confinement was introduced at the Eastern State Penitentiary as part of the "Pennsylvania" or separate system in Philadelphia in 1829, commentators attributed the high rates of mental breakdown to the system of isolating prisoners in their cells. Charles Dickens, who visited the Philadelphia Penitentiary during his travels to America, described the "slow and daily tampering with the mysteries of the brain to be immeasurably worse than any torture of the body".Prison records from the Denmark institute in 1870 to 1920 indicate that staff noticed inmates were exhibiting signs of mental illnesses while in isolation, revealing that the persistent problem has been around for decades.
In the twentieth century, Scandinavian countries such as Denmark have extensively used solitary confinement for prisoners in pretrial detention with the stated goal of preventing them from interfering in the investigation.Norwegian mass murderer Anders Breivik was held in solitary confinement, partly to protect him from other inmates. However, his complaint was partially upheld by the European Court of Human Rights in 2016.
The first comment by the Supreme Court of the United States about solitary confinement's effect on prisoner mental status was made in 1890 (In re Medley 134 U.S. 160).In it the court found that the use of solitary confinement produced reduced mental and physical capabilities.
The use of solitary confinement increased greatly during the COVID-19 pandemic in order to avoid spread of the virus in prisons.
The practice is used when a prisoner is considered dangerous to themselves or to others, is suspected of organizing or being engaged in illegal activities outside of the prison, or, as in the case of a prisoner such as a child molester or a witness, is at a high risk of being harmed by other inmates. The latter example is a form of protective custody. Solitary confinement is also commonly used as a form of punishment for violation of prison rules or other disciplinary infractions by an inmate.Solitary confinement is the norm in supermax prisons, where prisoners who are deemed dangerous or of high risk are held.
Solitary confinement as a disciplinary measure for prisoners in Europe was largely reduced or eliminated during the twentieth century.However, solitary confinement is still widely used across Europe for a variety of reasons.
The European Court of Human Rights distinguishes between complete sensory isolation, total social isolation and relative social isolationand notes that "complete sensory isolation, coupled with total social isolation can destroy the personality and constitutes a form of inhuman treatment which cannot be justified by the requirements of security or any other reason. On the other hand, the prohibition of contacts with other prisoners for security, disciplinary or protective reasons does not in itself amount to inhuman treatment or punishment."
The European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment, or CPT, defines solitary confinement as "whenever a prisoner is ordered to be held separately from other prisoners, for example, as a result of court decision, as a disciplinary sanction imposed within the prison system, as a preventive administrative measure or for the protection of the prisoner concerned".The CPT "considers that solitary confinement should only be imposed in exceptional circumstances, as a last resort and for the shortest possible time".
Italian prisoners subject to special surveillance ("14-bis regime") may be in de-facto solitary confinement.A person sentenced to multiple life sentences in Italy may be required by the Minister of Justice to serve a period of between 6 months to years in the "41-bis regime" of solitary confinement, subject to extension and review.
In 2015, segregation (solitary confinement) was used 7,889 times.54 out of 85,509 prisoners held in England and Wales in 2015 were placed in solitary confinement cells in a so-called 'Close Supervision Centre' (Shalev & Edgar, 2015:149), England and Wales' version of the US 'Supermax'.
The use of solitary confinement on juveniles and children, as elsewhere, has been a subject of contention. Critics argue that, in the United Kingdom, the state has a duty to "set the highest standards of care" when it limits the liberties of children.Frances Crook is one of many to believe that incarceration and solitary confinement are the harshest forms of possible punishments and "should only be taken as a last resort". Because children are still mentally developing, incarceration also should not encourage them to commit more violent crimes.
The penal system has been cited as failing to protect juveniles in custody.In the United Kingdom, 29 children died in penal custody between 1990 and 2006: "Some 41% of the children in custody were officially designated as being vulnerable". That is attributed to the fact that isolation and physical restraint are used as the first response to punish them for simple rule infractions. Moreover, Frances Crook argues that these punitive policies not only violate their basic rights but also leave the children mentally unstable and left with illnesses that are often ignored. Overall, the solitary confinement of youth is considered to be counterproductive because the “restrictive environment... and intense regulation of children” aggravates them, instead of addressing the issue of rehabilitation.
Solitary confinement is colloquially referred to in British English as "the block", "The Segregation Unit" or "the cooler".
Solitary confinement first arose in the United States in the 1700s among religious groups like the Quakers, who thought isolation with a Bible would lead to repentance and rehabilitation.
In the United States penal system, more than 20 percent of state and federal prison inmates and 18 percent of local jail inmates are kept in solitary confinement or another form of restrictive housing at some point during their imprisonment.Between 41,000-48,000 people were held in solitary confinement in 2001 in the United States, according to a study by Yale Law School. Of this number, 6,000 were being held in solitary confinement for over a year. The period of confinement can last from a few days to several decades. According to Homer Venters, former Chief Medical Officer for the New York City jail system, "Solitary confinement is utilised for tens of thousands of people for years at a time.” Many of these people will be held in a Supermax prison- high-tech prisons purposely designed to hold people in strict and prolonged solitary confinement.
As of 2021, there have been attempts in New York State to ban the use of solitary confinement for periods of more than 15 days, in line with UN recommendations against the use of torture.
The headquarters for the Bolivarian Intelligence Service (SEBIN) in Plaza Venezuela, Caracas, have an underground detention facility that has been dubbed La Tumba (The Tomb). The facility is located at the place that the underground parking for the Metro Caracas was to be located. The cells are two by three meters that have a cement bed, white walls, security cameras, no windows, and barred doors, with cells aligned next to one another so that there is no interaction between prisoners.Such conditions have caused prisoners to become very ill, but they are denied medical treatment. Bright lights in the cells are kept on so that prisoners lose their sense of time, with the only sounds heard being from the nearby Caracas Metro trains. Those who visit the prisoners are subjected to strip searches by multiple SEBIN personnel.
Allegations of torture in La Tumba, specifically white torture, are also common, with some prisoners attempting to commit suicide.Those conditions according to the NGO Justice and Process are intended to make prisoners plead guilty to the crimes that they are accused of.
Physicians have concluded that for those inmates who enter the prison already diagnosed with a mental illness, the punishment of solitary confinement is extremely dangerous in that the inmates are more susceptible to exacerbating the symptoms.Research indicates that the psychological effects of solitary confinement may encompass "anxiety, depression, anger, cognitive disturbances, perceptual distortions, obsessive thoughts, paranoia, and psychosis." A main issue with isolating prisoners who are known to have mental illnesses is that it prevents the inmates from ever possibly recovering. Instead, many "mentally ill prisoners decompensate in isolation, requiring crisis care or psychiatric hospitalization." It is also noted that if a prisoner is restrained from interacting with the individuals they wish to have contact with they exhibit similar effects.
The lack of human contact, and the sensory deprivation that often go with solitary confinementcan have a severe negative impact on a prisoner's mental state that may lead to certain mental illnesses such as depression, permanent or semi-permanent changes to brain physiology, an existential crisis, and death.
A 2013 systematic review published in Acta Psychiatrica Scandinavica concluded that solitary confinement was "associated with negative effects on mental health."
According to a March 2014 article in American Journal of Public Health , "Inmates in jails and prisons attempt to harm themselves in many ways, resulting in outcomes ranging from trivial to fatal."
Self-harm was seven times higher among the inmates where seven percent of the jail population was confined in isolation. Fifty-three percent of all acts of self-harm took place in jail. "Self-harm" included, but was not limited to, cutting, banging heads, self-amputations of fingers or testicles. These inmates were in bare cells, and were prone to jumping off their beds head first into the floor or even biting through their veins in their wrists.A main issue within the prison system and solitary confinement is the high number of inmates who turn to self-harm.
One study has shown that "inmates ever assigned to solitary confinement were 3.2 times as likely to commit an act of self-harm per 1,000 days at some time during their incarceration as those never assigned to solitary. These inmates assigned to solitary were 2.1 times as likely to commit acts of self-harm during the days that they were actually in solitary confinement and 6.6 times as likely to commit acts of self-harm during the days that they were not in solitary confinement, relative to inmates never assigned to solitary confinement."The study has concluded that there is a direct correlation between inmates who self-harm and inmates that are punished into solitary confinement. Many of the inmates look to self-harm as a way to "avoid the rigors of solitary confinement." Mental health professionals ran a series of tests that ultimately concluded that "self-harm and potentially fatal self-harm associated with solitary confinement was higher independent of mental illness status and age group."
Solitary confinement has been reported to cause hypertension, headaches and migraines, profuse sweating, dizziness, and heart palpitations.Many inmates also experience extreme weight loss due to digestion complications and abdominal pain. Many of these symptoms are due to the intense anxiety and sensory deprivation. Inmates can also experience neck and back pain and muscle stiffness due to long periods of little to no physical activity. These symptoms often worsen with repeated visits to solitary confinement.
Some sociologists argue that prisons create a unique social environment that do not allow inmates to create strong social ties outside or inside of prison life. Men are more likely to become frustrated, and therefore more mentally unstable when keeping up with family outside of prisons.Extreme forms of solitary confinement and isolation can affect the larger society as a whole. The resocialization of newly released inmates who spent an unreasonable amount of time in solitary confinement and thus suffer from serious mental illnesses is a huge dilemma for society to face. The effects of isolation unfortunately do not stop once the inmate has been released. After release from segregated housing, psychological effects have the ability to sabotage a prisoner's potential to successfully return to the community and adjust back to ‘normal’ life. The inmates are often startled easily, and avoid crowds and public places. They seek out confined small spaces because the public areas overwhelm their sensory stimulation.
In 2002, the Commission on Safety and Abuse in America, chaired by John Joseph Gibbons and Nicholas Katzenbach found that: "The increasing use of high-security segregation is counter-productive, often causing violence inside facilities and contributing to recidivism after release."
Solitary confinement is considered to be a form of psychological torture with measurable long-term physiological effects when the period of confinement is longer than a few weeks or is continued indefinitely.In October 2011, UN Special Rapporteur on torture, Juan E. Méndez, told the General Assembly's third committee, which deals with social, humanitarian, and cultural affairs, that the practice could amount to torture: "Considering the severe mental pain or suffering solitary confinement may cause, it can amount to torture or cruel, inhuman or degrading treatment or punishment when used as a punishment, during pre-trial detention, indefinitely or for a prolonged period, for persons with mental disabilities or juveniles." In November 2014. the United Nations Committee Against Torture stated that full isolation for 22–23 hours a day in super-maximum security prisons is unacceptable. The United Nations have also banned the use of solitary confinement for longer than 15 days.
The long-term psychological impacts of solitary confinement in South Africa, as well as deprivation and constraint torture techniques in prisons, were observed as analogous to those of post-traumatic stress disorder.
There is a scholarly consensus that solitary confinement is harmful, which has led to a growing movement to reduce or abolish the practice.
In immigration detention centers, reports have surfaced concerning its use against detainees in order to keep those knowledgeable about their rights away from other detainees.In the prison-industrial complex itself, reports of solitary confinement as punishment in work labor prisons have also summoned much criticism. One issue prison reform activists have fought against is the use of Security Housing Units (extreme forms of solitary confinement). They argue that they do not rehabilitate inmates but rather serve only to cause inmates psychological harm. Further reports of placing prisoners into solitary confinement based on sexual orientation, race and religion have been an ongoing but very contentious subject in the last century.
Research has shown that the routine features of prison can make huge demands on limited coping resources. After prison many ex-convicts with mental illness do not receive adequate treatment for their mental health issues, because health services turn them away. This is caused by restrictive policies or lack of resources for treating the formerly incarcerated individual.In a study focusing on women and adolescent men, those who had health insurance, received mental health services, or had a job were less likely to return to jail. However, very few of the 1,000 individuals in this study received support from mental health services.
Treating mentally ill patients by sentencing them into solitary confinement has captured the attention of human rights experts who conclude that "solitary confinement may amount to cruel, inhuman, or degrading treatment" that violates rights specifically targeting cruel, inhuman treatment.Health care professionals and organizations recognize the fact that solitary confinement is not ethical, yet the segregating treatment fails to come to a halt. "Experience demonstrates that prisons can operate safely and securely without putting inmates with mental illness in typical conditions of segregation." Despite this and medical professionals' obligations, segregation policies have not changed because mental health clinics believe that "isolation is necessary for security reasons." In fact, many believe that it is ethical for physicians to help those in confinement but that the physicians should also be trying to stop the abuse. If they cannot do so they are expected to undertake public advocacy.
The legality of solitary confinement has been frequently challenged over the past sixty years as conceptions surrounding the practice have changed. Much of the legal discussion concerning solitary confinement has centered on whether or not it constitutes torture or cruel and unusual punishment. While international law has generally begun to discourage solitary confinement's use in penal institutions, [ citation needed ]opponents of solitary confinement have been less successful at challenging it within the United States legal system.
UN Special Rapporteurs on Torture Manfred Nowak and Juan Méndez have "repeatedly unequivocally stated that prolonged solitary confinement is cruel, inhuman or degrading treatment, and may amount to torture", though their statements are not primary sources in international law. : 427
A 2005 law journal article argued America's detention system is far below the basic minimum standards for treatment of prisoners under international law and has caused an international human rights concern: "U.S. solitary confinement practices contravene international treaty law, violate established international norms, and do not represent sound foreign policy."
The examples and perspective in this section may not represent a worldwide view of the subject.(June 2020)
The 2013 California prisoner hunger strike saw approximately 29,000 prisoners protesting conditions.This statewide hunger strike reaching two-thirds of California's prisons began with the organizing of inmates at Pelican Bay State Prison. On 11 July 2011, prisoners at Pelican Bay State Prison began a hunger strike to "protest torturous conditions in the Security Housing Unit (SHU) there..." and to advocate for procedural and policy changes like the termination of the "debriefing process" which forces prisoners "to name themselves or others as gang members as a condition of access to food or release from isolation". More than 6,000 inmates throughout the California prison system stood in solidarity with these Pelican State Bay prisoners in 2011 by also refusing their food. Also in solidarity with the 2011 Pelican Bay prisoners on strike is the Bay Area coalition of grassroots organizations known as the Prisoner Hunger Strike Solidarity Coalition. This coalition has aided the prisoners in their strike by providing a legal support force for their negotiations with the California Department of Corrections and Rehabilitation (CDCR) and by creating and running a media based platform to raise support and awareness for the strikers and their demands among the general public.
Solitary confinement has served as a site of inspiration for protest-organizing against its use in and outside of prisons and conversely, as a response tactic for prisons to react to the protest-organizing of its prisoners. In March 2014, authorities at the Northwest Detention Center in Washington relegated multiple detainees to solitary confinement units after their participation in protests for the improvement of conditions within the facility and in solidarity with activist organizing against deportation escalations outside of the facility.
Scrutiny of super-maximum security prisons and the institutionalization of solitary confinement is accompanied by suggestions for alternative methods. In July 2013 the New York City Department of Correction transferred more seriously mentally ill inmates to an internal facility, similar to a hospital psychiatric ward, for more intensive therapy. Those with less severe mental illness who break disciplinary rules are still restricted to solitary confinement, but with increased hours of therapy and a behavioral intervention program.
A second alternative is to deal with long-term inmates by promoting familial and social relationships through the encouragement of visitations which may help boost morale. : 165 Familial counseling and support may be useful for inmates nearing the end of a long-term sentence that may otherwise exhibit signs of aggression, and prison rules and discipline should be clear, rational, and consistent, while inmates should be given objective goals to improve their situation.
In 2013 Maine reduced its then-full supermax solitary population by half and implemented "informal sanctions" of restricted priveliges, rather than solitary as punishment for every infraction.A 2013 Vera Institute of Justice report praised Washington state's use of alternative discipline to solitary and careful review and transition process when inmates enter and leave solitary, which began as a voluntary reform by prison officials 15 years prior.
Sensory deprivation or perceptual isolation is the deliberate reduction or removal of stimuli from one or more of the senses. Simple devices such as blindfolds or hoods and earmuffs can cut off sight and hearing, while more complex devices can also cut off the sense of smell, touch, taste, thermoception (heat-sense), and the ability to know which way is down. Sensory deprivation has been used in various alternative medicines and in psychological experiments. When deprived of sensation, the brain attempts to restore sensation in the form of hallucinations.
Pelican Bay State Prison (PBSP) is a supermax prison facility in Crescent City, California. The 275-acre (111 ha) prison takes its name from a shallow bay on the Pacific coast, about 2 mi (3.2 km) to the west.
Incarceration in the United States is a primary form of punishment and rehabilitation for the commission of felony and other offenses. The United States has the largest prison population in the world, and the highest per-capita incarceration rate. One out of every 5 people imprisoned across the world is incarcerated in the United States. In 2018 in the US, there were 698 people incarcerated per 100,000; this includes the incarceration rate for adults or people tried as adults. Prison, parole, and probation operations generate an $81 billion annual cost to U.S. taxpayers, with an additional $63 billion for policing. Court costs, bail bond fees, and prison phone fees generate another $38 billion in individual costs.
Prisoner abuse is the mistreatment of persons while they are under arrest or incarcerated. Prisoner abuse can include physical abuse, psychological abuse, sexual abuse, torture, or other acts such as refusal of essential medication.
Psychological punishments are punishments that aim to cause mental pain or discomfort in order to punish an individual. Psychological punishments are usually designed to cause discomfort or pain through creating negative emotions such as humiliation, shame and fear within an individual or by depriving the individual of sensory and/or social stimulation.
Red Onion State Prison (ROSP) is a supermax state prison located in unincorporated Wise County, Virginia, near Pound. Operated by the Virginia Department of Corrections (VADOC), it houses about 800 inmates. The prison opened in August 1998.
A prison, also known as a jail,gaol, penitentiary, detention center, correction center, correctional facility, lock-up, hoosegow or remand center, is a facility in which inmates are confined against their will and usually denied a variety of freedoms under the authority of the state as punishment for various crimes. Prisons are most commonly used within a criminal justice system: people charged with crimes may be imprisoned until their trial; those pleading or being found guilty of crimes at trial may be sentenced to a specified period of imprisonment. In simplest terms, a prison can also be described as a building in which people are legally held as a punishment for a crime they have committed.
Lesbian, gay, bisexual, transgender and queer (LGBTQ) people face difficulties in prison such as increased vulnerability to sexual assault, other kinds of violence, and trouble accessing necessary medical care. While much of the available data on LGBTQ inmates comes from the United States, Amnesty International maintains records of known incidents internationally in which LGBTQ prisoners and those perceived to be lesbian, gay, bisexual or transgender have suffered torture, ill-treatment and violence at the hands of fellow inmates as well as prison officials.
F-Type-Prisons, officially called F-type High Security Closed Institutions for the Execution of Sentences, are high-security prisons designated by Turkish Law 5275 on the Execution of Sentences.
In Italy, life imprisonment is the most severe punishment provided by law, and has an indeterminate length. Article 22 of the Italian Penal Code defines life imprisonment as "perpetual, and is taken for granted in one of the establishments destined for this, with the obligation of work and with night-time isolation", thus meaning that the sentence may last for the remainder of the convicted person's life. It is a mandatory punishment for aggravated cases of murder, aggravated cases of terrorism, felony murder in cases where serious violent offences result in death, using a weapon of mass destruction by causing an endemic through the spread of pathogenic germs in the case of a biological weapon, and mafia association under aggravated circumstances. It is also a possible punishment for terrorism, poisoning of water or food supplies, and treason.
A prisoner is a person who is deprived of liberty against their will. This can be by confinement, captivity, or forcible restraint. The term applies particularly to serving a prison sentence in a prison.
The 2013 California prisoner hunger strike started on July 8, 2013 involving over 29,000 inmates in protest of the state's use of solitary confinement practices and ended on September 5, 2013. The hunger strike was organized by inmates in long term solitary in the Security Housing Unit (SHU) at Pelican Bay State Prison in protest of inmates housed there that were in solitary confinement indefinitely for having ties to gangs. Another hunger strike that added to the movement started the week before in High Desert State Prison. The focus of the High Desert State Prison hunger strike was to demand cleaner facilities, better food and better access to the library.
In the United States penal system, upwards of 20 percent of state and federal prison inmates and 18 percent of local jail inmates are kept in solitary confinement or another form of restrictive housing at some point during their imprisonment. Solitary confinement generally comes in one of two forms: disciplinary segregation, in which inmates are temporarily placed in solitary confinement as punishment for rulebreaking; and administrative segregation, in which prisoners deemed to be a risk to the safety of other inmates, prison staff, or to themselves are placed in solitary confinement for extended periods of time, often months or years.
Mentally ill people are overrepresented in United States jail and prison populations relative to the general population. There are three times more seriously mentally ill persons in jails and prisons than in hospitals in the United States. Scholars discuss many different causes of this overrepresentation including the deinstitutionalization of mentally ill individuals in the mid-twentieth century; inadequate community mental health treatment resources; and the criminalization of mental illness itself. The majority of prisons in the United States employ a psychiatrist and a psychologist. There is a general consensus that mentally ill offenders have comparable rates of recidivism to non-mentally ill offenders. Mentally ill people experience solitary confinement at disproportionate rates and are more vulnerable to its adverse psychological effects. Twenty-five states have laws addressing the emergency detention of the mentally ill within jails, and the United States Supreme Court has upheld the right of inmates to mental health treatment.
Prisoners in New Zealand are afforded numerous, but not all, human rights. Criticisms by a United Nations report in 2014 highlighted various issues that constitute ill-treatment of prisoners, such as remand prisoners being routinely held on lock-down for 19 hours per day, an increasingly strict prison regime, and the mixing of adult and youth prisoners.
A prison is a place where people condemned to a custodial sentence or awaiting their trial are contained. Prisons are also used to try to reintegrate inmates into society in order to prevent recidivism. French prisons are overflowing and the penitentiary personnel is understaffed. In 2003 the European Committee for the Prevention of Torture (CPT), an organ of the European Council reported "inhumane and degrading treatment" in French prisons.
While studies have shown the effects of solitary confinement to be detrimental to some inmates, solitary confinement of women has particular consequences for women that may differ from the way it affects men. Solitary confinement rates for women in the United States are roughly comparable to those for men and about 20% of prisoners will be in solitary confinement at some point during their prison career.
Criminal justice reform addresses structural issues in criminal justice systems such as racial profiling, police brutality, overcriminalization, mass incarceration, and recidivism. Criminal justice reform can take place at any point where the criminal justice system intervenes in citizens’ lives, including lawmaking, policing, and sentencing.
The Prisoner Human Rights Movement was launched in 2011 by Pelican Bay State Prison inmates in response to large numbers of inmates being moved from general prison populations to solitary-confinement units after allegations of gang affiliation or political organizing. Its goal is to improve living conditions for inmates in California.
Prisoners' Justice Day is a solidarity movement that takes place annually on August 10. The movement began in Canada in 1974 in support of prisoners’ rights and to remember all the people who have died of unnatural deaths while incarcerated. The first Prisoners' Justice Day was held at the Millhaven Institution on August 10, 1975, on the first anniversary of Edward Nolan's death. In addition to a day of mourning, six prisoners took part in an eighteen-day hunger strike. In 1976, August 10 was recognized as a memorial day where prisoners would strike in opposition to the use of solitary confinement and to protest inmate conditions within the Prison System by going on a one-day hunger strike and refusing to work.
Most prison systems feature solitary confinement among their repertoire of disciplinary punishments for prisoners.
Rule 44: For the purpose of these rules, solitary confinement shall refer to the confinement of prisoners for 22 hours or more a day without meaningful human contact. Prolonged solitary confinement shall refer to solitary confinement for a time period in excess of 15 consecutive days. Rule 45: (1) Solitary confinement shall be used only in exceptional cases as a last resort, for as short a time as possible and subject to independent review, and only pursuant to the authorization by a competent authority. It shall not be imposed by virtue of a prisoner’s sentence.