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82 national lawyers guild reviewtwo private facilities [was] 1.06 percent.” 151 Similarly, a 1999 report by theFederal Bureau of Prisons noted that privately operated facilities used morestaff, had a higher turnover rate, and had “much higher escape rates fromsecure institutions” than the public federal system did. 152 In one of the mostegregious displays of ineffective incarceration, the Northeast Ohio CorrectionCenter in Youngstown, Ohio—a spec CCA prison—witnessed six escapesin its first fifteen months of operation. 153 Five of the six escapees were convictedmurderers, and all of them were maximum-security inmates. 154 Austinand Coventry noted that operational flaws such as escapes “were linked toinexperienced staff, [and] inadequate training.” 155Ineffective incarceration also presents dangers to prison guards, administratorsand inmates. 156 Over the past decade there have been numerous reports detailingviolence and sub-standard prison conditions within the private sector:In 2007, the ACLU filed suit against the Department of HomelandSecurity and CCA, alleging that a federal immigration facility near SanDiego was housing three inmates in two bed cells. 157In Idaho, a recent report indicated that the State’s only privately ownedprison had an inmate violence rate three times higher than that of thepublic facilities. 158A report by the Texas Youth Commission from September 26 to October2, 2007 listed 21 major operational and security issues at the Coke CountyJuvenile Justice Center in Bronte, Texas. 159 The report detailed “flagrant”violations such as double-bunking youths, racial segregation, and aninmate work schedule for hours between 10:00 p.m. and 4:30 a.m. 160In addition to the six escapes, the Northeast Ohio Correction Centersaw seventeen stabbings, numerous assaults on prison personnel, andtwo murders in under a year and a half of operation. 161 Ultimately, thetown of Youngstown filed a successful suit on behalf of the inmatesalleging that the inmates were in danger due to the company’s housingpractices. 162And in 2000, Wackenhut relinquished its contract for a juvenile center inJena, Louisiana after the Department of Justice filed a suit alleging physicaland verbal abuse, and the inappropriate use of pepper spray. 163While shocking, these stories do not appear to be aberrations. Accordingto the Department of Justice, in total there are greater numbers of inmateon-inmateassaults in private prisons (35.1 percent) as compared to publicfacilities (25.4 percent). 164While we often think of incarceration as an end product in criminal lawtheory, for most individuals, incarceration is only temporary. And when a