Serving Frozen Time: Federally Funding Education and Incorporating Technology into Prisons is Key to Reducing Recidivism Among Prisoners

Policies that prevent and/or limit educational opportunities and technology use in prisons are inadequate, especially today’s society. For over a century, prison education was encouraged because it provided actual proof that recidivism rates dropped drastically when prisoners were awarded college degrees before their release. From 1965 to 1994, prisoners received Federal Pell Grants until the Violent Crime Control Act and Law Enforcement Act of 1994 revoked the money and withdrew college programs from prisons almost overnight, leaving prisoners without constructive outlets to occupy their copious amounts of time. Soon afterwards, private organizations began funding education programs to helped prepare prisoners for life after release, and in doing so, contributed to decreased violence within prisons. Despite these successes, providing education is not enough in today’s society. The United States is one of the most technologically innovative and advanced countries in the world, and we did not get here by barring people from receiving educations. Incarcerating people for decades and then releasing them into an unrecognizable world almost guarantees their return to prison; therefore, in order to best facilitate prisoners’ chance at success upon release, prisons should provide prisoners with increased technology use and opportunities to learn how to use modern devices. To do this, the Federal Government should provide prisoners with access to Pell Grants again, and ensure that prisons have the necessary means to comply with standards regarding treatment of prisoners.

First and foremost, prison policies that limit education and technology use in prisons are inadequate because they disregard criminal justice standards set by the American Bar Association (“ABA”). The ABA created a set of standards regulating the treatment of prisoners (“ABA standards”) that is meant to guide policymakers and practitioners working with prisons in running them effectively.[i] Though the standards are not laws, prisons should aim to follow them as closely as possible to constructively utilize prisoners’ time while incarcerated. Due to the lack of opportunities for prisoners to earn high school and college degrees, however, it is clear that many prisons do not (or are unable to) abide by these guidelines. Because the majority of state and federal prisons are government-funded, the government should take action to implement and fund new policies in which prisoners are encouraged to seek an education and learn skills that will facilitate reintegration. [ii]

This first standard seemingly imposes a duty upon prisons to ensure the prisoners are prepared for life upon release. ABA standard 23–1.1(b) states that “imprisonment should prepare prisoners to live law-abiding lives upon release. Correctional authorities should facilitate prisoners’ reintegration into free society by … sustained planning for such reintegration.”[iii] Though “sustained planning” is not explicitly defined, several other standards elaborate on what prisons should do to facilitate prisoners’ reintegration, such as ensuring education and educational programs are accessible. ABA standard 23–1.2(a)(vii) says correctional authorities should “provide prisoners with opportunities to participate in constructive activity and rehabilitative programs” and standard 23–3.1(a)(iii) demands correctional facilities “include appropriate … visitation, recreation, education, and program space.”[iv] Prison should serve as a place for rehabilitation and education to ensure prisoners are equipped with the necessary knowledge that will help them thrive outside prison, but current policies prevent this goal.

Implementing educational programs in prisons will not only ensure that prisoners have degrees that will help them obtain employment upon release, but keeping prisoners well-versed in current technology trends will ensure they do not enter a world that is completely unfamiliar to them. Standard 23–8.2(b) states that prisoners should receive individualized programming plans with access to “educational opportunities, … vocational and job readiness training… and other programs designed to promote good behavior in the facility and reduce recidivism,” demonstrating that the ABA is aware that providing education and practical skills courses to prisoners results in lower recidivism rates.[v] Standard 23.8–2(c) recommends that prisoners “obtain a foundation in basic literacy, numeracy, and vocational skills” while incarcerated, and if that period is expected to last more than six months, prisons should offer “high school equivalency classes, post-secondary education … [and] programs designed to facilitate re-entry into the workforce upon release.”[vi] The best way to prepare prisoners for life outside prison is not only to offer them college educations while incarcerated, but to also familiarize them with technology used in everyday life. Otherwise, prisoners reenter society without skills and knowledge necessary to succeed, often returning to prison soon after release.

Some people, however, are almost guaranteed to become incarcerated as a result of society’s failure to provide adequate education and opportunities to succeed. Many students in poor cities who attend underfunded schools often become involuntary participants in the school-to-prison pipeline. The racial profile of prisons is disproportionately representative of the racial profile of the United States; despite only making up 1/3 of the population in the United States, non-white prisoners (Black, Hispanic, Asian) make up 60% of the population within prisons nationally (in New York they account for 75%).[vii] Minorities are historically more likely not to pursue a college degree due to a personal history of poverty, neglect, and inadequate resources at schools.

Moreover, underfunded and understaffed schools are typically attended by minorities who are then over-regulated by police officers that schools hire to maintain order. Studies show that black students are three times more likely to be expelled or suspended than white students and are punished more often for trivial acts like cursing and being disrespectful.[viii],[ix] Sometimes these interactions between school officers and students result in arrests that lead to the student’s expulsion or suspension. When schools deprive students of constructive activity with which to fill their days, they often become involved in criminal activity and eventually end up in prison where their opportunities to finish school are extremely limited.[x] Most students who have been subjected to the school-to-prison pipeline enter prison without a high school diploma.[xi] To put an end to the school-to-prison pipeline, public schools need better funding to keep students engaged, off the streets, and ultimately out of prison. Prisons also need the government’s support to provide those who have been incarcerated with opportunities to become educated and participate in interactive workshops to prepare them for life outside prison.

It could be argued that not preparing prisoners for life outside prison in the modern era is negligent. If ABA Standard 23–1.1(b) creates a duty for correctional authorities to “facilitate prisoners’ reintegration into free society”, then failing to provide prisoners with opportunities to successfully reintegrate breaches that duty.[xii] Releasing a prisoner into the world after years of incarceration during which he received no formal education will likely result in his return to prison. Prisoners who are able to participate in college programs, however, often have an increased likelihood that they will find jobs that allows them to live a crime-free life.[xiii]

Approximately 92% of prisons are publicly funded, but since 1994, public funds for incarcerated people to obtain education in prison have been extremely limited.[xiv] Instead, private enterprises like the Bard Prison Initiative (“BPI”) and Hudson Link have provided prisoners with the means to earn degrees and become prepared to enter the real world. For over a century prior to 1994, however, education was considered essential in prisons and both the government and private entities funded prisoners’ endeavors to become educated while incarcerated.

Educating prisoners is not a radical idea; education in some form has been part of the prison system since the early 1800’s. Initially, chaplains only taught prisoners about religion, but eventually taught them to read and write because education was believed to assist in the spiritual enlightenment of prisoners.[xv] In the 1870’s, education came to be viewed as rehabilitative when the American Prison Association (Later the American Correctional Association) published its Declaration of Principles. Its tenth principle held education in high regard, proclaiming it a “vital force in … reformation” and “a matter of primary importance in prisons, and should be carried to the utmost extent.”[xvi] In 1877 Elmira Reformatory in New York instituted a mandatory education program though which prisoners could earn privileges and parole.[xvii] Within a decade, the program began attracting prominent visitors to be “Sunday lecturers” in its trade workshops, elementary-level, and advanced classes.[xviii]

This rehabilitative view of educating prisoners was not widely shared until at least the 1970’s, though. In 1960 only nine states offered college-level courses; the majority of them were taught as “correspondence education”, meaning prisoners received instructional materials in the mail, rather than in-person lectures.[xix] In 1965, President Johnson signed the Higher Education Act which extended financial aid to incarcerated individuals.[xx] For almost 30 years, federal Pell Grants funded thousands of prisoners’ access to college courses in hundreds of prisons.[xxi]

Studies on the effects on education in prisons gained popularity after Johnson signed the Higher Education Act. In 1969, the University of Minnesota launched Project Newgate (“Newgate”) in five states with the goal of determining whether prisoners could benefit from higher education, and whether higher education in prisons could reduce crime rates and recidivism.[xxii] Newgate focused primarily on teaching life skills that would benefit the former prisoners upon re-integration into society, and one participant said “Newgate alleviates and sometimes prevents this nightmare of post-release adjustment.”[xxiii] In order to ensure that the prisoners utilized their newly learned skills as soon as possible, Newgate limited its enrollment to those who were likely to be paroled within six to eighteen months after admission to the project.[xxiv]

Having few resources and little support while readjusting to life outside prison often results in released prisoners violating parole or committing another crime to return. One 2019 study concluded that 64% of violent offenders and 46% of nonviolent offenders return to prison within eight years.[xxv] Consequently, successfully reducing recidivism rates is one of the most important components when it comes to reintegration of prisoners. A 1971 study done at D.C.’s National Training School shared concerns with Newgate regarding effective recidivism efforts and the passage of time. The study concluded that recidivism rates after three years for those who participated in the college program were almost average, suggesting that “the absence of continued reinforcement of positive behaviors following release” resulted in prisoners’ return to prison.[xxvi] Without structure outside of prison, many are doomed to return. Providing education to prisoners gives them the opportunity to gain employment outside of prison and regain control of their lives.

Prisons do not seem to be averse to providing prisoners with education, legislation just prevents them from doing so. In 1971, prisoners at New York’s Attica Correctional Facility staged a rebellion that left 43 dead and during negotiations, the prisoners demanded better living conditions, including increased employment opportunities and access to education.[xxvii] Prisons across the country obliged, and by 1982 there were over 350 prison college programs with over 27,000 prisoners participating.[xxviii] In 1988, the American Correctional Association said prisons are “overflowing with the young, the poor, the illiterate, the unemployed, the minorities … their chances for law-abiding behavior [outside] will not be enhanced if nothing is done to deal with their deficiencies while incarcerated.[xxix] Despite this assertion, fewer than ten years later President Clinton signed the Violent Crime Control Act and Law Enforcement Act of 1994 (“1994 Crime Bill”) that banned prisoners from using federal Pell Grants for college programs while incarcerated.[xxx]

The passage of the 1994 Crime Bill decimated the number of prison education programs across the country. In the early 90’s there were over 770 programs and in 1997, only eight remained.[xxxi] The Crime Bill did not affect prisons that received private funding for education, so private entities formed and used donations to fund prison education programs; by 2005 there were twelve programs available.[xxxii] In 1999, Bard College’s undergraduate students launched the Bard Prison Initiative (“BPI”) at Eastern Correctional Facility. Both the prisoners and administrative personnel showed “overwhelming enthusiasm” for the initiative, and today BPI is in six prisons and has conferred over 600 college degrees from Bard College. [xxxiii],[xxxiv] A graduate who now serves as the Government Affairs Officer in charge of expanding BPI’s presence in prisons said that to meet prisoners’ demands of education, public funding needs to be given to private programs. In doing so, he hopes that the public will “acknowledge the amount of humanity and potential that we have locked away in this country.”[xxxv]

Hudson Link is another privately funded enterprise whose goal is to provide prisoners with an education and prepare them for life outside of prison. Since 1998, Hudson Link has conferred over 700 degrees from eight colleges and now operates in five New York prisons.[xxxvi] Additionally, at $5,000 per year per prisoner, Hudson Link’s program is roughly $55,000 cheaper than paying for a year of reincarceration; an appealing return on investment for taxpayers.[xxxvii] Both BPI and Hudson Link’s successes have saved New York taxpayers at least $21 million a year because its graduates boast a recidivism rate of just 2%, while New York State’s average rate is 43%.[xxxviii] During their 20+ year existences, Hudson Link and BPI have proven through low recidivism rates that when given the opportunity to obtain an education, prisoners flourish. Prisons that do not offer educational opportunities see almost half of their population return at some point, costing taxpayers hundreds of millions of dollars a year. The 1994 Crime Bill was disastrous for prisoners and for taxpayers alike, but prisoners suffered in unimaginable ways.

Sean Pica was a member of Hudson Link’s first graduating class and is now its Executive Director. He recalled the confusion in Sing Sing after the Crime Bill went into effect, saying prisoners “couldn’t believe” that it was happening, that “colleges literally came in the next day and started packing up their boxes, all the books,” leaving participants with unfinished degrees and an overabundance of free time.[xxxix] Prisoners often spend between 10–23 hours in their cells every day, and one Hudson Link graduate praised the program as being “something to do every night.” [xl],[xli] Without having classes and assignments to fill their time, prisoners turn to watching TV and mingling in prison yards, consequently leading to an increase in gang activity and violence within the prisons.[xlii] John J. Lennon, a prisoner who is currently earning a bachelor’s degree at Sing Sing while working as a freelance journalist, criticized the 1994 Crime Bill and blamed it for preventing his friends from succeeding both inside and outside of prison. He wrote that by taking away prisoners’ education, the bill “created a culture of ignorance, violence, and hopelessness” and ensured prisoners were “ill-prepared for life on the outside.”[xliii] He further admonishes the effects of the bill, blaming it for “incapacitat[ing]” prisoners” and giving “troubled young men” very few opportunities to succeed.[xliv]

Prison education programs often act as a deterrent against crime and violence within prisons. Sean Pica spoke about how Hudson Link stipulates that prisoners must avoid disciplinary infractions while enrolled, otherwise they lose their spot in the program. [xlv] He admired how even those who were not enrolled would abide by these rules if they were friends with someone whose future could be jeopardized by one mistake.[xlvi] Additionally, a professor at Eastern described how determined to remain in the program the students were: they “remained remarkably calm, even when … provoked” by the “imposition of endless petty rules.” [xlvii] College programs within prisons are extremely selective and prisoners could lose their spot in the program in an instant for a disciplinary infraction; it is clear that none of them want to risk losing their chance at success outside prison, so they choose to avoid situations that might get them in trouble.[xlviii]

Hudson Link and the Bard Prison Initiative go beyond just educating prisoners, but continuously facilitate their graduates’ transition into society. The organizations maintain strong alumni networks that contribute to invaluable internship and career opportunities and provide resources such as laptops and interview attire.[xlix],[l] Prisoners who have spent long periods of time incarcerated might reenter a world that is almost unrecognizable due to the changes in society and advances in technology during their incarceration. The actions taken by BPI and Hudson Link demonstrate that the two organizations understand that simply earning a college degree is not enough to ensure success today, prisoners need technology education within prisons, too.

Although prisoners who complete college programs while incarcerated will leave prison with “booksmarts,” they will not necessarily leave with the same “streetsmarts” they had when they entered. Prisoners who have been isolated from society for years have missed crucial advances in technology that society now utilizes in daily life. One former prisoner admitted that “in society, if you don’t have basic computer skills, it’s more and more difficult to navigate.”[li] Now more than ever, recently released prisoners struggle tremendously trying to make a life for themselves after having such little exposure to modern technology while incarcerated. Therefore, a well-rounded education in prison involves implementing technology into learning and providing hands-on workshops that familiarize them with modern devices.

Without downplaying the physical and emotional toll that any prison sentence imposes on someone, being incarcerated sixty years ago was not necessarily as detrimental to one’s daily life as prolonged incarceration is today. In the 1960’s, color TV was relatively new and by the mid-1970’s, the biggest technological advances included the use of home smoke detectors, GPS, and barcodes on products in stores.[lii] Until the 1980’s, the transition from prison to the real world was not significantly hindered by ever-changing technology; generally, one could assimilate back into society without worrying how much their daily life will be impacted by something that was invented while they were incarcerated.

Incarceration over a period of 30 years in the modern era, however, would likely leave a newly released prisoner in a state of disbelief. Someone who entered prison in the 1990’s was accustomed to using reference encyclopedias at the library to do research, but by 2000, people had the entirety of human knowledge at their fingertips thanks to Google.[liii] Ten years later, people carried a combination computer + camera + telephone + boombox in their back pocket and could order DNA tests that illustrate their ancestral profiles from the internet.[liv] Today, doctors can 3D print limbs for amputees, people own electric self-driving cars, and make purchases just by looking at their cellphones. For those who have not spent decades in prison, daily life is easily navigable because we have kept up with technology’s progression, but someone who was isolated from modern society for 30 years and has not used devices that we consider normal would have immense difficulty adapting.

Many prisoners have spoken about the hardships they endured after being released with little understanding as to how much the world has really changed. Jose Saldana, for example, faced the reality that society had evolved past his understanding almost immediately upon release. He told a story about how a friend who met him at the prison gates handed him an iPhone to answer a FaceTime call from his wife, but could not understand what was happening.[lv] Sean Pica talked about how simply knowing of something’s existence in prison is not enough to understand it in real life, using the internet as an example.[lvi] Otis Johnson, who was released at 69 after serving 44 years, was amazed to see peanut butter and jelly in the same jar at the grocery store and concluded that everyone he saw wearing headphones in Times Square was a member of the CIA.[lvii] One released inmate who had spent two decades incarcerated could not figure out how to operate motion sensor things like sinks and toilets upon his release.[lviii] Another inmate who spent 22 years incarcerated said that a lack of understanding of technology “can become the catalyst of sending [released prisoners] right back as soon as they get out” and compared the hardship akin to moving to China without speaking the language.[lix] Preventing prisoners from interacting with and learning how to use modern technology before they are release prevents them from having smooth transitions from prison to the real world.

This is not to say that prisoners are completely isolated from technology while incarcerated. Some are so desperate for human connection that they pay employees to smuggle in cell phones, even risking a stint in solitary confinement.[lx] Despite costing between $300-$1,000, cell phones are viewed as a cheaper option than the prison-sanctioned phone calls that can cost up to $1 per minute.[lxi] Prisons claim the ban on cell phones is to promote safety and prevent crimes outside of prison, but prisoners believe the ban is in place so prisons can make a profit.[lxii] Although prisoners do use the cellphones to facilitate drug deals or plan crimes, many use the phones to keep in contact with their friends and family or to post Tik Toks depicting life in prison.[lxiii] One recently released inmate said he posted Tik Toks to deter younger generations from making decisions that might put them in prison, while another said he does it for “human connection” and because his friends use the app.[lxiv]

While some prisoners obtain devices like smartphones, most do not and are unprepared for how prevalent technology is upon release. Institutions understand the difficulties involved with transitioning out of prison, but often do not have the resources to address the issues. In a 2018 effort to facilitate reintegration, Colorado’s Department of Corrections spent $180,000 to initiate a virtual reality (“VR”) program for prisoners.[lxv] Prisoners who have been incarcerated since they were juveniles but are close to being released attend a class in which they wear a VR headset and virtually complete tasks. [lxvi] After virtually doing laundry, using a self-checkout kiosk at the grocery store, and swiping a debit card, prisoners reacted to the changes outside prison walls. One participant said that learning how to use an iPhone or a debit card is more important than other skills that can be developed later in the reintegration process, and another cried while saying he would not have recognized a modern-day grocery store without this program.[lxvii] Similar to Apple’s workshops in which people join classes and learn how to use their iPhones and laptops, John Jay College offers a free course called “Tech 101” to teach former prisoners the basics of the internet. They learn how to use sites like Facebook and Twitter, set up Gmail accounts, and become accustomed to Microsoft Office.[lxviii] Prisons should move towards a model of rehabilitation that incorporates technology use into educational programs to adequately prepare prisoners for life after release.

Many prisons actually do have Wi-Fi-disabled tablets with pre-loaded apps and websites for both educational programs and personal use. The tablets, however, often charge prisoners by the minute to use them, which is outrageous considering that those who work typically make less than one dollar per hour.[lxix] Nonetheless, the tablets are an asset because they provide thousands of inmates with more access to education and resources in preparation for life outside. However, some people worry that because there are so few studies on the effects of modern technology in prison programs, the quality of the programs might worsen if they expand.[lxx] In fact, a senior manager at an prison education-focused nonprofit stated that there are so many unknows as to what learning format works best in prisons because “it’s just been so neglected from a research point of view for a long time.” [lxxi] While prisons should move to incorporate technology in their education and college programs, they need to ensure that in doing so, prisoners have free access to live in order to best prepare for release.

Technology use in prison is limited mainly due to security concerns, but creating closed networks that only link to sites that host job posts or housing rentals would have an enormous impact on prisoners preparing to reenter society.[lxxii] One current prisoner stated that internet access would provide him with a level “self-sufficiency that [he] can only dream of.”[lxxiii] Furthermore, just as participation in college programs deters violence, access to tablets keeps prisoners on their best behavior. Prison employees say that the computers and tablets keep prisoners occupied, thus lowering the risk of altercations.[lxxiv] One former inmate said access to tablets changed the “whole dynamic” of prisons, in that any violent confrontations could result in loss of tablet privileges.[lxxv] He also said that tablets helped revive his relationships with his family before his release, which is a common theme among prisoners. [lxxvi]

Technology should become a mainstay in prisons to ensure prisoners are able to maintain contact with their families when in-person visitation is difficult. ABA standard 23.1.2(a)(vi) advises that prisons provide for inmates maintaining healthy relationships with their families. [lxxvii] While communication can be achieved via many mediums (emails, texting, phone calls, videochats), in-person visits remain the ideal form of communication. Many factors, however, prevent prisoners from having regular in-person visits with their friends and family, and this is where technology can help — some are imprisoned hours from home, while varying security levels restrict visitation privileges for others. Sometimes a prisoner’s only options to communicate with friends and family are their once-monthly phone calls or by writing letters, but these policies pose problems for the roughly 60% of prison inmates who are illiterate.[lxxviii] Tablets would enable prisoners with varying education levels to videochat with family, as well as facilitate their journey to becoming not only literate, but educated, too. Furthermore, the President of Georgetown University’s Prisons and Justice Initiative implored people to support education initiatives within prisons by detailing the benefits prisoners derive from education while incarcerated: providing prisoners with access to education results in safer communities, more stable families, and lower costs and taxpayer savings.[lxxix]

Private programs like BPI and Hudson Link take the time to ensure prisoners are adequately prepared to restart their lives, but nonprofit organizations should not be the one of the sole sources of prison education funding. While there are states whose government allots money to fund prison education programs, this is still an inadequate level of involvement. The Federal Government should intervene and reallocate funds from different departments to promote the idea that prisoners deserve a second chance at life upon release. A study funded by the Department of Justice concluded that “incarcerated individuals who participated in correctional education were 43 percent less likely to return to prison within three years than prisoners who did not participate in any correctional education programs.”[lxxx] As a result of this study, the Obama Administration announced that it believes in funding education and job training for incarcerated individuals because the results are “clear”: recidivism rates save taxpayer dollars and create safer communities. [lxxxi]

The Administration pledged to provide Pell Grants to 12,000 incarcerated individuals in the hopes that giving prisoners the opportunity to get an education will motivate them to create and live successful, crime-free lives upon release. In April 2020, The Trump administration expanded the program, doubling the number of participating colleges from 67 to 130 and enabling even more prisoners to regain control of their futures.[lxxxii] However, of the 2.2 million people incarcerated in the United States, only about 24,000 receive federal funding for prison education programs today.[lxxxiii] More needs to be done to ensure that prisoners are not blindly released into the world after spending potential decades sitting idly by without learning anything, expected to navigate this new way of life on their own.

The Shawshank Redemption depicts the sad reality that many prisoners face after release when they are given little opportunity to succeed. The film portrays a prisoner (“Brooks”) struggling and ultimately failing to adapt after serving a 50-year sentence. Brooks struggled at his grocery bagging job and even fantasized about committing violent crimes as a way to get sent “home” to prison, but subsequently hangs himself at his halfway house because he was not prepared for life outside of prison.[lxxxiv] Though this is fiction, the idea is rooted in fact. Without being afforded the opportunity to obtain the proper credentials and skillset to succeed outside prison, prisoners are doomed to return, or worse.

Clearly, policies that prevent and/or limit educational opportunities and technology use in prisons are inadequate. Education is one of the only documented methods that effectively lowers recidivism rates because it provides prisoners with real opportunities to succeed and avoid reentering prison. In order to best accommodate and facilitate prisoners’ chance at success upon release, Congress should revoke the restrictions imposed by the 1994 Crime Bill and reinstate prisoners’ overarching right to Federal Pell Grants. In doing so, the private organizations that currently fund prison education programs might be relieved of some pressure to perform, but more importantly, even more prisoners will be given opportunities they might not have had access to outside of prison. Furthermore, any new policies should stipulate that prisoners receive a well-rounded education that not only confers upon them degrees that will facilitate in their employment endeavors, but an education that prepares them mentally, socially, and technologically for the outside world.

[i] ABA, Criminal Justice Standards https://www.americanbar.org/groups/criminal_justice/standards/

[ii] Kara Gotsch and Vinay Basti, Capitalizing on Mass Incarceration: U.S. Growth in Private Prisons. The Sentencing Project (Aug. 2 2018) https://www.sentencingproject.org/publications/capitalizing-on-mass-incarceration-u-s-growth-in-private-prisons/#VI.%20Appendix:%20State%20Profiles%20in%20Prison%20Privatization

[iii]ABA, Criminal Justice Standards: General Principles

[iv] Id.

[v] ABA, Criminal Justice Standards: Rehabilitation and Reintegration https://www.americanbar.org/groups/criminal_justice/standards/

[vi] Id.

[vii] Wendy Sawyer, Mass Incarceration: The Whole Pie 2020 Prison Policy Initiative (Mar. 24, 2020). https://www.prisonpolicy.org/reports/pie2020.html, https://www.prisonpolicy.org/profiles/NY.html

[viii] ACLU, School-To-Prison Pipeline https://www.aclu.org/issues/juvenile-justice/school-prison-pipeline

[ix] Lucius Couloute, Getting Back on Course: Educational exclusion and attainment among formerly incarcerated people, Prison Policy Initiative (Oct. 2018) https://www.prisonpolicy.org/reports/education.html

[x] Id.

[xi] Michael Sainato, US Prison System Plagued by High Illiteracy Rates. The Observer (Jul. 18 2017) https://observer.com/2017/07/prison-illiteracy-criminal-justice-reform/

[xii]ABA, Criminal Justice Standards: General Principles

[xiii] U.S. Dept. of Ed., Literacy Behind Prison Walls 59. National Center for Education Statistics (1994) https://nces.ed.gov/pubs94/94102.pdf

[xiv] Kara Gotsch and Vinay Basti, Capitalizing on Mass Incarceration: U.S. Growth in Private Prisons.

[xv] Rick Linden & Linda Perry, The Effectiveness of Prison Education Programs, 6 J. Offender Counseling, Services & Rehab. 43 (1982).

[xvi] American Prison Association, Declaration of Principles Adopted and Promulgated By the 1870 Congress of the National Prison Association (1870). https://www.aca.org/aca_prod_imis/docs/Exec/1870Declaration_of_Principles.pdf

[xvii] New York Correction History Society, Elmira (2003) http://www.correctionhistory.org/html/chronicl/docs2day/elmira.html

[xviii] Id.

[xix] Linden at 43. Michael Thomas, Former Inmates’ Perceptions and Beliefs About the Value of Earning a High School Diploma 94 (2019) (Ph.D. dissertation, University of Missouri-Kansas City)

[xx] Prison Fellowship, Higher Education in Prison https://www.prisonfellowship.org/resources/advocacy/conditions/higher-education-in-prison/#

[xxi] Id.

[xxii] Richard J. Clendenen, John R. Ellingston & Ronald J. Severson, Project Newgate: The First Five Years, 25 CRIME & DELINQUENCY 55 (1979).

[xxiii] Id. At 58, 60

[xxiv] Id. At 60

[xxv] Matthew Clarke, Long Term Recidivism Studies Show High Arrest Rates, 30 Prison Legal News 5, May 2019. https://www.prisonlegalnews.org/news/2019/may/3/long-term-recidivism-studies-show-high-arrest-rates/

[xxvi] Linden at 50

[xxvii] Ian Buruma, Uncaptive Minds New York Times (Feb. 20, 2005) https://www.nytimes.com/2005/02/20/magazine/uncaptive-minds.html

[xxviii] Wendy Sawyer, Since You Asked: How did the 1994 crime bill affect college prison programs? Prison Policy (August 22, 2019) https://www.prisonpolicy.org/blog/2019/08/22/college-in-prison/

[xxix] T.A. Ryan, Correctional Education: Past is Prologue to the Future 60 J. of Correctional Education 46 (1995).

[xxx] Wendy Sawyer, Since You Asked: How did the 1994 crime bill affect college prison programs?

[xxxi] Id.

[xxxii] Buruma, Uncaptive Minds

[xxxiii] Id.

[xxxiv] Bard Prison Initiative, The College: Comprehensive academic engagement https://bpi.bard.edu/our-work/the-college/

[xxxv] Interview by Madeleine Carlisle with Dyjuan Tatro, Gov’t Affairs Officer, BPI (Nov. 26 2019) https://time.com/5737213/ken-burns-lynn-novick-college-prison-documentary/

[xxxvi] Hudson Link, What We Do: Fact Sheet http://www.hudsonlink.org/what-we-do/fact-sheet/

[xxxvii] Id.

[xxxviii] Id. Only Hudson Link’s website gave an estimate as to how much money lower recidivism rates save, so it’s obviously higher when BPI is factored in.

[xxxix] Erica L. Green, Senate Leaders Reconsider Ban on Pell Grants for Prisoners New York Times (Feb. 15 2018) https://www.nytimes.com/2018/02/15/us/politics/pell-grants-prisoners.html

[xl] Alan Travis, Prisoners spend “too long in cells” The Guardian (Jun 1, 2008) www.theguardian.com/society/2008/jun/02/prisonsandprobation

[xli] Hudson Link, Success Stories http://www.hudsonlink.org/success-stories/

[xlii] Id.

[xliii] John J. Lennon, How Biden Killed Prison Education, The Atlantic (Nov. 6 2019) https://www.theatlantic.com/politics/archive/2019/11/how-biden-killed-educational-opportunity-prisons/601120/

[xliv] Id.

[xlv] Sean Pica, Guest Speaker in Prisoner’s Rights at Pace Law School (Nov. 11 2020)

[xlvi] Id.

[xlvii] Buruma, Uncaptive Minds

[xlviii] Buruma, Uncaptive Minds

[xlix] Bard Prison Initiative, Reentry & Alumni Affairs https://bpi.bard.edu/our-work/reentry-alumni-affairs/

[l] Hudson Link, What We Do: Alumni Affairs http://www.hudsonlink.org/what-we-do/

[li] Eillie Anzilotti, This course helps former prisoners learn the tech they missed in jail, Fast Company (Dec. 6 2018) https://www.fastcompany.com/90272675/this-course-helps-prisoners-catch-up-on-the-tech-advances-they-missed-in-prison

[lii] Wikipedia, Timeline of Historic Inventions https://en.wikipedia.org/wiki/Timeline_of_historic_inventions

[liii] Id. At 2000’s

[liv] Id. At 2010’s

[lv] Jose Saldana, Guest Speaker in Prisoner’s Rights at Pace Law School (Nov. 18 2020)

[lvi] Pica (Nov. 11 2020)

[lvii] Al Jazeera English, My Life After 44 Years in Prison, Youtube (Nov 24. 2015) https://www.youtube.com/watch?v=OrH6UMYAVsk&feature=emb_title&ab_channel=AlJazeeraEnglish

[lviii] YourCautionaryTale, People sentenced in the 80s-2000s what modern world change shocked you the most? Reddit (2019) https://www.reddit.com/r/AskReddit/comments/cait4o/people_sentenced_in_the_80s2000s_what_modern/et92lcx/?utm_term=32243709345&utm_name=163029e2-bf8a-11e9-b066-0e67039e19dc&utm_content=timestamp&utm_source=embed&utm_medium=comment_embed&context=3

[lix] Kari Paul and Michael Baldwin Jr. “It made me feel human again”: the tech easing inmates’ isolation The Guardian (Apr. 18 2020) https://www.theguardian.com/us-news/2020/apr/18/coronavirus-prisoners-isolation-technology

[lx] CBS San Francisco, Smuggled Cellphones A Growing Problem in California Prisons (Oct. 17 2012) https://sanfrancisco.cbslocal.com/2012/10/17/smuggled-cellphones-a-growing-problem-in-california-prisons/

[lxi] Id.

[lxii] Kim Severson and Robbie Brown, Outlawed, Cellphones Are Thriving in Prisons The New York Times (Jan 2, 2011) https://www.nytimes.com/2011/01/03/us/03prisoners.html?_r=1

[lxiii] Id., Vice News, Prisoners Are Going Viral on Tik Tok, Youtube (Nov 12, 2020) https://www.youtube.com/watch?v=d53jCvZ38NQ&ab_channel=VICENews

[lxiv] Vice News, Prisoners Are Going Viral on Tik Tok

[lxv] Matt Clark, Some Prisons are Using Virtual Reality for Reentry Prison Legal News (July 2, 2019) https://www.prisonlegalnews.org/news/2019/jul/2/some-prisons-are-using-virtual-reality-reentry-and-other-programs/

[lxvi] Id.

[lxvii] Vice News, Inmates Are Using VR For a Chance to Get Out of Prison, YouTube (Dec. 27, 2017) https://www.youtube.com/watch?v=s7hPBZxHvk4&ab_channel=VICENews

[lxviii] Anzilotti, This course helps former prisoners learn the tech they missed in jail,

[lxix] Diana Kruzman, In U.S. Prisons, Tablets Open Windows to the Outside World, Reuters (7/18/18) https://www.reuters.com/article/us-usa-prisons-computers/in-u-s-prisons-tablets-open-window-to-the-outside-world-idUSKBN1K813D

[lxx] All Things Considered, Tablets Offer Educational Opportunities in Prison, But Quality Varies NPR (Jan 2 2020) https://www.npr.org/transcripts/793134372

[lxxi] Lilah Burke, Blackboard Behind Bars Inside Higher Ed (Dec. 10 2019) https://www.insidehighered.com/digital-learning/article/2019/12/10/online-education-comes-prisons

[lxxii] Nancy La Vigne, Elizabeth Davies, Tobi Palmer, and Robin Halberstadt, Release Planning for Successful Reentry: A Guide for Corrections, Service Providers, and Community Groups 33 Justice Policy Center (Sept 2008). https://www.urban.org/sites/default/files/publication/32056/411767-Release-Planning-for-Successful-Reentry.PDF

[lxxiii] David Simonsen, Doing Frozen Time: A 30-Year Inmate’s View Of Modern Technology Forbes (Feb 17, 2017) https://www.forbes.com/sites/realspin/2017/02/15/doing-frozen-time-a-30-year-inmates-view-of-modern-technology/?sh=3016bbcc4bc1

[lxxiv] Kruzman, In U.S. Prisons, Tablets Open Windows to the Outside World, Reuters

[lxxv] Kari Paul and Michael Baldwin Jr. “It made me feel human again”: the tech easing inmates’isolation.

[lxxvi] Id.

[lxxvii] ABA, Criminal Justice Standards: General Principles

[lxxviii] Michael Sainato, US Prison System Plagued by High Illiteracy Rates. The Observer (Jul. 18 2017) https://observer.com/2017/07/prison-illiteracy-criminal-justice-reform/

[lxxix] Burke, Blackboard Behind Bars: Inside Higher Ed

[lxxx] Press Release, The White House, White House Announces New Commitments to Fair Chance Higher Education Pledge (Sept. 14 2016) https://www.ed.gov/news/press-releases/fact-sheet-white-house-announces-new-commitments-fair-chance-higher-education-pledge

[lxxxi] Press Release, The White House, 12,000 Incarcerated Students to Enroll in Postsecondary Educational and Training Programs Through Education Department’s New Second Chance Pell Pilot Program (June 24, 2016) https://www.ed.gov/news/press-releases/12000-incarcerated-students-enroll-postsecondary-educational-and-training-programs-through-education-departments-new-second-chance-pell-pilot-program

[lxxxii] Press Release, The White House, Secretary DeVos Expands Second Chance Pell Experiment, More than Doubling Opportunities for Incarcerated Students to Gain Job Skills and Earn Postsecondary Credentials (April 24, 2020) https://www.ed.gov/news/press-releases/secretary-devos-expands-second-chance-pell-experiment-more-doubling-opportunities-incarcerated-students-gain-job-skills-and-earn-postsecondary-credentials

[lxxxiii] Id. I’m also just assuming it’s 24,000 because the Trump’s (surprising) expansion doubled the size of the program. I couldn’t find actual numbers, though.

[lxxxiv] The Shawshank Redemption (Columbia Pictures, 1995)