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Pace Law Review Prison Oversight Sourcebook Article 15 Government Model Reflections 2010

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Pace Law Review
Volume 30
Issue 5 Fall 2010
Opening Up a Closed World: A Sourcebook on
Prison Oversight

Article 15


Reflections on a Government Model of
Correctional Oversight
Richard T. Wolf
New York City Board of Correction

Recommended Citation
Richard T. Wolf, Reflections on a Government Model of Correctional Oversight, 30 Pace L. Rev. 1610
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Reflections on a Government
Model of Correctional Oversight
Richard T. Wolf, Esq.
Beginning in the 1970s, corrections institutional reform
litigation and resulting judicial oversight brought dramatic
improvements in conditions of confinement and prisoner access
to health and mental health care in many state prison systems
and local jails. Some jurisdictions relied exclusively on the
courts for correctional oversight and failed to develop nonjudicial oversight mechanisms. Judicial oversight required
governors, mayors and legislatures to provide funds to meet
mandates imposed on corrections systems by court orders and
consent decrees. Persistent prisoners’ attorneys and ongoing
court involvement forced correctional systems to work to
maintain the improvements.
In the late 1990s however, state and local governments
began invoking provisions of the Prison Litigation Reform Act
(“PLRA”) to end ongoing court involvement in correctional
oversight.1 Decades of judicial oversight of corrections came to
an end. Jurisdictions that relied exclusively on litigation and
the courts to provide oversight of the “closed world” of
corrections suddenly found themselves without any external
corrections oversight mechanism. It is unclear whether the
absence of judicial oversight will contribute to the deterioration
of conditions in affected correctional systems, or whether it
already has done so. However, elected officials can be expected
to devote limited resources to public works and maintenance
projects that directly affect the lives of taxpaying voters (for
example, schools, hospitals, and roads) rather than to
Richard T. Wolf, Esq., is Executive Director of the New York City
Board of Correction. The views expressed herein are exclusively those of the
author, and do not reflect the views of the Board.
1. Prison Litigation Reform Act of 1995, Pub. L. No. 104-134, § 802, 18
U.S.C. § 3626 (2006).





correctional facilities—closed, “total institutions” that
taxpayers do not see.
The fact that correctional facilities are “closed worlds” is
the compelling argument for outside, independent scrutiny.
Another is the costs: taxpayers should be able to have windows
into the institutions costing over $65 billion each year.2 Other
governmental institutions and operations are subject to
oversight. Corrections should be no exception.
It is my view that even with the best efforts of wellintentioned professional corrections administrators, conditions
inside prisons and jails are at risk for erosion unless
jurisdictions develop, implement, and support effective nonjudicial correctional oversight to fill the PLRA-inspired
correctional oversight vacuum.
The New York City Board of Correction (“Board” or “BOC”)
is one model of non-judicial oversight. Presented below is a
description of the model, its strengths and weaknesses, and
some thoughts about how the BOC model might inform
jurisdictions that are seeking to establish effective oversight of
The New York City Board of Correction
A. Structure and Authority
The New York City Board of Correction (the “Board”) is a
non-judicial, government correctional oversight mechanism. It
is a hybrid that defies easy categorization because it is both a
regulatory body and a monitoring and inspecting organization.
The Board is a City agency, separate and apart from the
City’s Department of Correction (“DOC”), the large, complex
bureaucracy that operates the City’s jails. The Board’s broad
mandates are to establish minimum standards “for the care,
custody, correction, treatment, supervision, and discipline of all
2. See Bureau of Justice Statistics, U.S. Department of Justice, Crime
Online, (select
parameters “all governments,” “corrections,” and “2005”) (last visited Mar. 15,
2010) (compiling report showing that, in 2005, the total estimated amount of
direct expenditures by federal, state, and local governments for corrections
was $65,091,212).




[Vol. 30:5

persons held or confined under the jurisdiction of the
department,”3 and to evaluate the performance of the NYC
Department of Correction.4 The Board’s present structure is
designed to promote independent oversight though ongoing
monitoring and inspection, but it was originally created for
entirely different reasons.
The Board began as a citizens’ advisory board, established
in 1957 by then Mayor Robert Wagner at the urging of his
Corrections Commissioner, Anna M. Kross.5
The Mayor
appointed nine unsalaried members to be advocates for
resources to help Commissioner Kross improve conditions of
confinement in the City’s jails, increase prisoner programming,
and support her management reforms.6 The original Board
members were authorized to inspect City jails and to offer longrange planning proposals, but the volunteer members were
given no staff, and for many years they relied upon
Department of Correction employees for clerical support.7
The Board was fundamentally restructured when, in 1975,
New York City’s voters endorsed by referendum a plan to
reshape the Board into a stronger and more independent
correctional oversight agency.8 New provisions of the City
Charter changed how members were to be appointed, and gave
the Board additional authority and powers.9
The idea behind revising the Board’s structure was
formally to establish and maintain an arms-length relationship
between the Board of Correction and the Department of
Correction.10 Instead of vesting sole appointing authority with
the Mayor, the revised Charter provisions (which remain in
effect today) provided that three unsalaried Board members be
appointed by the Mayor, three by the legislature (the City
Council), and three by the Mayor upon nomination by the
judiciary (the Presiding Justices of the First and Second
3. N.Y. CITY CHARTER § 626(e) (2009).
4. Id. § 626(c)(4).
5. N.Y. City Bd. of Corr., About BOC—History of BOC, (last visited Mar. 15,
6. Id.
7. See id.
8. Id.
9. Id.
10. Id.




Judicial Departments).11 Appointments to six-year terms were
to be made on a rotating basis.12
The new Charter provisions redefined the authority of the
BOC, converting it from an advisory board to a regulatory body
by directing the Board to establish minimum standards.13 The
minimum standards are binding and enforceable regulations.14
The voters also gave the Board important monitoring and
inspection tools. First, the BOC was authorized to hire its own
Second, Board members and staff were granted
unfettered access to all DOC facilities and records.16 Finally,
the Board was given subpoena power and was authorized to
conduct investigations and to hold public or private hearings on
any matter within the jurisdiction of the DOC.17

Compliance Monitoring and Jail Inspection: BOC’s Field
Operations Unit

The Board has a small but experienced staff. The staff
members track a variety of jail violence indicators, and respond
to and investigate inmate suicides, homicides and other
unusual incidents. However, their primary responsibilities are
to inspect the City’s jails, and to monitor for compliance with
three sets of minimum standards established by the Board.
These regulate conditions of confinement, mental health
services, and health care. The Board has a staff of fourteen
employees, eight of whom comprise a full-time field operations
11. N.Y. CITY CHARTER § 626(a) (2009). See also N.Y. City Bd. of Corr.,
supra note 5.
12. § 626(a). See also N.Y. City Bd. of Corr., supra note 5.
13. § 626(e). See also N.Y. City Bd. of Corr., supra note 5.
14. See § 1041.
15. Id. § 626(b).
16. Id. § 626(c)(1)-(2).
17. Id. § 626. See also N.Y. City Bd. of Corr., supra note 5.
18. The Department of Correction employs 8,662 uniformed staff and
1,611 civilians, confines more than 13,000 inmates in eight major facilities on
Rikers Island, two off-Island “borough” jails, and two hospital prison wards.
Its budget for fiscal year 2010 is projected to exceed $1 billion. Mayor’s
Management Report, Preliminary Fiscal 2010, at 126-27 (Feb. 2010). The
Board’s total budget will be approximately $950,000. N.Y. CITY OFFICE OF




[Vol. 30:5

The Board’s field representatives walk the jails each day,
serving as BOC’s “eyes and ears” in the facilities. Their job is
to promote stable jail environments by receiving and
addressing complaints from inmates and staff, and by helping
to smooth the delivery of basic services. Their goal is to
identify small minimum-standards compliance issues and
facility-operations problems and bring them to the jail’s
administration for resolution before they ripen into major
Indeed, approximately ninety-five percent are
successfully resolved in the facility and never come to the
attention of DOC’s central office administrators.
Increasingly, the Board’s efforts have been directed
towards ensuring that inmates receive timely access to medical
and mental health care. Providing timely access to decent
medical services and mental health care in correctional
settings requires close cooperation and coordination between
correctional health providers and custody staff. Occasionally,
despite the best of intentions, inmates with serious medical
problems sometimes fall between the cracks. When they
identify such inmates, BOC field representatives get them to
needed care. Then, our staff identifies systemic issues, if any,
which contributed to the problem.
Systemic problems
sometimes are resolved at the individual jail. Oftentimes,
however, they require involvement of central office
Both DOC and the Department of Health and Mental
Hygiene are committed to full compliance with minimum
standards. This is evidenced by the prompt corrective actions
that typically are taken by jails’ uniformed and correctional
health managers when incidents of non-compliance are
reported by BOC field representatives. When noncompliance
with a section of the minimum standards is not corrected at the
facility level, the Board brings the matter to the appropriate
agency’s central office administrators for resolution.
C. Minimum Standards
The Board has promulgated three sets of minimum




1. Conditions of Confinement
The original Minimum Standards for New York City
Correctional Facilities (promulgated in 1978) included
provisions calling for non-discriminatory treatment of inmates,
and regulated inmate access to courts, religious services, visits,
recreation, access to the outside world (telephones, mail,
publications, and packages), and overcrowding.19
standards remained substantially unchanged until 1985, when
the BOC amended provisions regulating overcrowding.20
In November, 1983, the City’s inability to comply with
orders of the Federal District Court had led to the release of
613 inmates.21 The outraged responses of the media and
politicians caused the City to embark on a major building plan
to add bed capacity.22 However, new beds could not be opened
quickly enough to meet the steady influx of pre-trial detainees,
and another release was feared. Recognizing the public safety
risks presented by another release, the Board decided to
increase the allowable capacities of dormitory housing units by
twenty-five percent.23
However, mindful of the risks to
institutional safety and security of allowing DOC to house more
detainees in dormitories, the Board imposed dormitory capacity
limits, required sound-separated dayrooms, and incorporated
into the amended standard the City’s Building Code
requirements for ratios of operable toilets, showers and sinks to
inmates in jail dormitories.24

19. See N.Y. City Bd. of Corr., Rules—Minimum Standards,
visited Mar. 4, 2010).
20. Id.
21. See id.
22. Id.
23. See id.
24. At the conclusion of a lengthy review and deliberative process, the
Board passed numerous amendments to the Minimum Standards. It
considered, but declined to modify, Standards provisions governing square
footage per inmate in dormitories and dormitory capacities. The Board left
intact the requirement that inmates be offered an opportunity to take outdoor
exercise daily. See N.Y. City Rules, tit. 40, ch. 1, § 1-06 (2009), available at
Also, the revised Standards
continue to require that DOC operate a visiting program five days per week.
Id. § 1-09.




[Vol. 30:5

2. Mental Health Minimum Standards
In the 1970s and early 1980s, the BOC issued
comprehensive investigative reports of individual inmate
suicides. New York State’s “deinstitutionalization” policies
emptied the state’s large mental hospitals. Increasingly,
detainees with mental illness entered the City’s jails. The
Board held public hearings in the early 1980s to explore the
quality and availability of mental health services provided to
inmates, and concluded that mental health minimum
standards were needed.
The Board worked with the
Departments of Health, Mental Health, Correction, the Mayor’s
Office, and contract service providers to develop consensus
standards, drawing upon recommendations from local mental
health professionals and national professional organizations.
When the Board adopted the Mental Health Minimum
Standards in 1985, New York City became the first local
jurisdiction in the country to voluntarily require itself—
without being compelled to do so by the courts—to provide
appropriate levels of quality mental health staffing and other
resources. The results were immediate and significant. In
1986, the first full year of Standards implementation, there
were three suicides—down from eleven the preceding year.
Key provisions of the mental health standards include
mental health screening for all incoming inmates within 24
hours of arrival in DOC custody, training of correctional and
medical staff in recognizing signs and symptoms of mental and
emotional disorders, special mental health observation housing
areas for those inmates in need of close supervision, 24-hour
access to mental health services personnel for emergency
psychiatric care, and an inmate observation aide program that
employs carefully-selected, trained inmates to help uniformed
staff monitor those inmates identified as potential suicide
3. Health Care Minimum Standards
Using the same inter-agency collaborative approach that
led to the creation of the Mental Health standards, the Board
drew upon the expertise of health professionals from City
agencies and the contract health services provider to develop




comprehensive Health Care Minimum Standards (1991).
These require that the quality of medical services for inmates
must be consistent with “legal requirements, accepted
professional standards and sound professional judgment and
practice.”25 The Health Care Standards require that an
inmate’s medical intake screening must occur within 24 hours
of entering DOC custody, and weekday sick call must be
provided within 24 hours of request.26 Timely access to followup care and specialty clinics on Rikers Island and at off-Island
hospitals must be provided.27
Other sections regulate
pharmaceutical services, dental, vision and eye care, pregnancy
and child care, and diagnostic services.28 The Standards also
contain provisions addressing medical records, privacy and
confidentiality, the right to refuse treatment, and quality
D. Observations
The Board’s roles as regulatory body, inspector and
performance evaluator create unusual opportunities and
challenges. Presented below are some observations about nonjudicial oversight of local jails that have been extrapolated from
New York City’s experience with the Board of Correction.
1. Local Jail Standards can Address Challenges Unique to
the Local Jail
The local minimum standards established by the Board of
Correction (discussed above) regulate conditions in the City’s
jails only. The standards do not affect jails in the fifty-seven
counties outside of New York City. A state agency, the New
York State Commission of Correction, has established
standards for the New York State prisons, and separate
standards for all county jails.30 Thus, New York City is


Id. § 3-01(a)(1).
Id. §§ 2-02(b)(1), 2-03(b)(1).
Id. § 2-04(c)(5).
See id. §§ 3-02, 3-05, 3-06.
See id. §§ 3-06 to 3-09.
See N.Y. COMP. CODES R. & REGS. tit. 9 (2009).




[Vol. 30:5

regulated by two separate sets of standards.
Fundamental and important differences distinguish New
York City’s jails from those in the non-City counties. The most
obvious is size. Currently, New York City’s open and available
bed capacity is 14,326 beds, and the Department of Correction
confines 13,377 inmates.31 By contrast, many of the non-City
counties are rural areas that are sparsely populated, and most
of the jails have very small capacities. Excluding the seven
largest non-City counties, the other 50 non-City counties have
a combined total of 9,774 beds—an average jail capacity of 195
beds per county.32
Provisions in the State standards typically are less
stringent than those set by the Board for New York City. This
is to be expected: after all, the State standards apply to all
counties in New York State, including many small jails with
limited resources. For example, the New York State standards
do not require jails to minimize inmates’ visitors waiting time,
or to provide visitors with access to bathrooms and drinking
water, or to a sheltered waiting area,33 which are all required
by the Board’s Minimum Standards for New York City.34
There are important differences between outdoor exercise
provisions as well.
The State standards lack the City
requirement that outdoor recreation areas must provide for
direct access to sunlight and air.35 The State standards require
that an outdoor exercise area must contain at least 1500
square feet,36 an area that would be much too small to
accommodate many Rikers Island jail populations, two of which
exceed 2,000 inmates.
Regulations governing small county jails sometimes are
YORK, 5:00 A.M. CENSUS REPORT (Sept. 29, 2009) (on file with PACE LAW
32. New York State Comm’n of Corr., Information as Provided by
Facilities via Jails Daily Population Reporting System (Sept. 29, 2009) (on
file with PACE LAW REVIEW). According to the Commission of Correction, the
seven largest non-City county jails are Albany, Erie, Monroe, Nassau,
Onondaga, Suffolk and Westchester, with a combined capacity of 10,299 beds.
33. See N.Y. COMP. CODES R. & REGS. tit. 9, § 7008.
34. See N.Y. City Rules, tit. 40, ch. 1, § 1-09(b)(3)-(4).
35. See N.Y. COMP. CODES R. & REGS. tit. 9, § 7028.4; N.Y. City Rules, tit.
40, ch. 1, § 1-06(b).
36. N.Y. COMP. CODES R. & REGS. tit. 9, § 7028.4.




inapplicable to the unique management challenges presented
by the second largest municipal detention system in the
Delivery of correspondence—including legal
correspondence—presents a good example. Male inmates on
Rikers Island frequently are transferred among seven large,
separate jail commands, and this increases the challenge of
providing timely mail delivery.
Timely delivery is a
substantially greater management challenge for the City’s
large system than it is for a small local jail, which may have
fewer than 200 beds. To ensure timely mail delivery, the City’s
local Minimum Standards require delivery within 48 hours.37
Presumably a schedule would not be needed to ensure timely
delivery in a 200-bed system, so state regulations do not
establish a schedule.38
2. Sometimes Local Oversight is Best Able to Address the
Needs of the Local Jail
The interests of local jurisdictions may conflict with those
of the state. When this occurs, local jails can benefit from local
oversight. An important example involved the prolonged
confinement of “state ready” prisoners in New York City jails.
“State ready” prisoners are prisoners who have been sentenced
to serve time in state prison, but who remain in local jails
pending transfer to a state facility. During a sustained period
of severe overcrowding in the late 1980s and early 1990s, the
New York State Department of Correctional Services (“DOCS”)
slowed dramatically its acceptance of newly-sentenced
prisoners. Because its prisons were severely overcrowded,
DOCS allowed state-readies to languish in local jails.
Frustrated city jail officials were unable to demand publicly
that the State take custody of its prisoners, because corrections
overcrowding was but one of many City-State issues that were
in play at the time. The City’s daily inmate census continued
to grow rapidly.
To accommodate the ever-increasing
population, the City converted two homeless shelters and two
ferries into make-shift jails. It entered into a contract with the
State to house almost 1,500 sentenced misdemeanants in two
37. N.Y. City Rules, tit. 40, ch. 1, § 1-11(d)(1).
38. See N.Y. COMP. CODES R. & REGS. tit. 9, § 7004.




[Vol. 30:5

State facilities hundreds of miles north of New York City, near
the Canadian border. In May, 1991, the daily inmate census
reached an all-time high of 22,630.
The Board of Correction exercised its role as advocate for
the City’s jail system when, month after month, it reported
publicly on increasing jail violence and attributed the increase
to overcrowding tied to the state-readies backlog. The Board
also cited the cost to the City of housing “overdue” state-ready
inmates, an expense that exceeded $1 million per week for
many months.
The Board advocated for the local jail system. Had jail
oversight instead been performed by a state-wide entity, there
would have been no one arguing that the state’s failure to take
timely custody was harming the correction officers, inmates,
and taxpayers in New York City.
Instead, the Board’s
persistence in drawing public attention to the issue resulted in
a swifter resolution.
3. A Structure Designed to Promote
Oversight Entity is Very Important


The Board was in a position to speak out and focus public
attention on the state-ready problem because of its structure.
As noted above, the nine members are nominated by three
different authorities.
For complex political reasons, the Mayor’s corrections
commissioner could not comment publicly on the State’s failure
to take custody of prisoners that rightfully should have been in
state custody. The Board was not similarly constrained, as its
unsalaried members were not required to take direction from
the Mayor. The members’ independence allowed them to focus
squarely on the corrections overcrowding problem, without
having to weigh their importance against the other issues then
being negotiated between the City and the State.
4. A Daily On-Site Presence Facilitates
Inspections and Compliance Monitoring


The Board of Correction’s approach to oversight centers on
ongoing compliance monitoring and facility inspection by
experienced, well-trained field representatives. The daily




presence of field representatives enables them to observe jail
operations without creating disruption among inmates or staff.
By seeking to resolve problems at the lowest level within the
institution, field representatives encourage line staff and
inmates alike that their complaints will be addressed discreetly
and objectively. Daily inspections and compliance monitoring
provide correctional oversight that is constructive because they
allow for the early identification of issues requiring resolution.
Early identification reduces the likelihood that small problems
will fester and become major ones.
5. A Local Oversight’s Understanding of Local Jail
Conditions Yields Solutions Tailored to Local Needs
An important benefit of a local oversight’s daily presence in
a local jail is the knowledge that the local oversight acquires
regarding conditions peculiar to the local jail. This knowledge
can be applied to the local jail’s unique problems to fashion jailspecific solutions. An example: shortly after the Department of
Correction moved its central punitive segregation area to a
newer jail on Rikers Island, Board staff reported a significant
increase in stabbing and slashing incidents, and noted that
most incidents were occurring in two areas, the recreation yard
and the law library. The Board urged DOC administrators to
adopt new procedures to address the increased violence. First,
the Board recommended that DOC subdivide the punitive
segregation yard to reduce the number of inmates who took
recreation in the same place at the same time. The Board
argued that this approach would provide staff with greater
control and improve inmate safety, and cited the successful
implementation of subdivided outdoor recreation areas in a
New York State prison. Second, the Board suggested that DOC
consider providing legal research opportunities to punitive
segregation inmates in their cells, rather than in the library.
Inmate interviews established that large numbers of inmates
were afraid to go to the law library and were unable to engage
in legal research. We urged that DOC experiment with a fully
auditable cell system, whereby inmates could call the legal
coordinator in the law library, discuss a legal issue, and obtain
copies of research materials for use in the cell. We insisted
that the alternative system provide legal research




[Vol. 30:5

opportunities as promptly as would a visit to the law library.
Both BOC recommendations were implemented.
6. The “Golden Key” of Unfettered Access is Indispensable
to Effective Monitoring
When Federal District Court Judge Morris Lasker would
visit New York City jails during the longstanding Benjamin39
class-action litigation, he would be taken through freshlypainted corridors to inspect dormitories selected by the
Department of Correction. Employees were known to plant
flowers in front of the jails he was inspecting. Inmates
reported that they were urged to remain silent during the
Judge’s tours.
Any oversight organization that must make appointments
in advance to inspect correctional facilities operates at a severe
Inspectors cannot be confident that the
conditions they observe accurately reflect the conditions that
prevail in the facility. Furthermore, unless they are able to
speak in confidence with prisoners and with staff, inspectors
are unlikely to be told about problems in the institution.
Oversight by appointment is not without benefit, but it lacks
the potential to identify incipient problems. This in turn limits
the organization’s value to the correctional system for which it
provides oversight.
7. A Non-Judicial Oversight Entity Must be Assured of
Ongoing, Adequate Funding
Structure alone cannot assure an oversight’s independence
or viability. The oversight organization must be adequately
resourced. If, as is the case with the Board of Correction, the
oversight entity provides a regular, daily presence throughout
a correctional system, the oversight must employ enough staff
to do so.
Unfortunately the Board’s revised City Charter provisions
do not include a requirement that assures adequate funding.
Funding has been the Board’s Achilles heel.

39. See Benjamin v. Malcolm, 495 F. Supp. 1357 (S.D.N.Y. 1980).




The Charter notes only that the Board may appoint
“professional, clerical, and support personnel within
appropriations.”40 The practical effect of this language is to
vest with the Mayor considerably more control over the Board
than the other nominating authorities, because the Mayor
dominates the budget process. This never was more apparent
than in 1994 when former Mayor Rudolph Giuliani, angered by
a Board member’s comments that were critical of the
Corrections Commissioner, attempted to eliminate the Board
by eliminating its budget.41 By declaring his intention to no
longer provide funding for the Board’s staff, the Mayor
challenged the Board’s independence.
Ultimately, Mayor Giuliani’s attempt to “zero-out” the
Board from the City budget failed, because the City Council
refused to accede to the Mayor’s plan. The Council must
approve the City budget, and it was able to negotiate
restoration of some of the Board’s funding. However, the
Mayor’s efforts were not entirely unsuccessful. The budget
compromise that was reached resulted in a fifty percent
reduction in the Board’s staff.
The extent to which the Board’s budget drama chilled its
ability to accurately and fully report on jail conditions and the
Department of Correction’s compliance with minimum
standards is unclear. But there certainly has been a lasting
effect. The smaller Board Field Operations Unit is unable to
investigate inmate and staff complaints as promptly as before,
which presents the danger that “fixable” problems may go
unattended and become more acute. Budget cuts also resulted
in the loss of most of the Board’s support staff. This has
limited the Board’s ability to issue timely reports on
monitoring activities.
Independent non-judicial correctional oversight promotes
safe, secure, and humane correctional environments for staff
and inmates. The Board’s structure is designed to maintain
40. N.Y. CITY CHARTER § 626(b) (2009).
41. Steven Lee Myers, Giuliani Weighs Sharp Cutbacks, Including a
New Severance Offer, N.Y. TIMES, Oct. 9, 1994, at A1.




[Vol. 30:5

independent oversight, and its daily field staff presence
promotes effective inspections and compliance monitoring.
The New York City Board of Correction’s local jail
oversight model may be useful to jurisdictions that are
mechanisms, or modifying existing ones. Local and state-wide
correctional oversight organizations could benefit by
incorporating elements of the model into their structures and




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