learning". Many prisons in the United States are overcrowded. For example, California's 33 prisons have a total capacity of 100,000, but they hold 170,000 inmates. Many prisons in California and around the country are forced to turn old gymnasiums and classrooms into huge bunkhouses for inmates. They do this by placing hundreds of bunk beds next to one another, in these gyms, without any type of barriers to keep inmates separated. In California, the inadequate security engendered by this situation, coupled with insufficient staffing levels, have led to increased violence and a prison health system that causes one death a week. This situation has led the courts to order California to release 27% of the current prison population, citing the Eighth Amendment's prohibition of cruel and unusual punishment. The three-judge court considering requests by the Plata v. Schwarzenegger and Coleman v. Schwarzenegger courts found California's prisons have become criminogenic as a result of prison overcrowding. In 2005, the U.S. Supreme Court case of Cutter v. Wilkinson established that prisons that received federal funds could not deny prisoners accommodations necessary for religious practices. According to a Supreme Court ruling issued on May 23, 2011, California — which has the highest overcrowding rate of any prison system in the country — must alleviate overcrowding in the state's prisons, reducing the prisoner population by 30,000 over the next two years. Solitary confinement is widely used in US prisons, yet it is underreported by most states, while some do not report it at all. Isolation of prisoners has been condemned by the UN in 2011 as a form of torture. At over 80,000 at any given time, the US has more prisoners confined in isolation than any other country in the world. In Louisiana, with 843 prisoners per 100,000 citizens, there have been prisoners, such as the Angola Three, held for as long as forty years in isolation. In 1999, the Supreme Court of Norway refused to extradite American hashish-smuggler Henry Hendricksen, as they declared that US prisons do not meet their minimum humanitarian standards. In 2011, some 885 people died while being held in local jails (not in prisons after being convicted of a crime and sentenced) throughout the United States. According to federal statistics, roughly 4,400 inmates die in US prisons and jails annually, excluding executions. As of September 2013, condoms for prisoners are only available in the U.S. State of Vermont