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or more than i O years, corrections professionals and others concerned about the treatment of prisoners have despaired over conditions in California's prisons. Crowding, violence, racial segregation, abysmal medical care, an obstructionist corrections union. and a state budget crisis have combined to bring the system to the point of constitutional meltdov,n. In 2008. a state appellate court found conditions of "'extreme peril to the safety of persons and property,'' and a three-judge federal court confirmed the existence of a "substantial risk to the health and safety of the men and women who work inside these prisons and the inmates housed in them." (See CCPOA v. Schwarzenegger, 77 Cal. Rptr. 3d 844. 854 (Cal. App. Ct. 2008); Coleman v. Schwarzenegger, 2009 WL 330960 (Feb. 9, 2009).) California's situation is extreme and atypical, but its lessons have not been lost on other jurisdictions struggling to cope with greatly expanded prison populations in a time of severe budget constraints. Nor have they been lost on the legal profession.


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