than in any other country in the world. "Mass incarceration" became a serious social and economic problem, as each of the 2.3 million American prisoners costs an average of about $25,000 per year. Recidivism remained high, and useful programs were often cut during the recession of 2009–2010. In 2011, the U.S. Supreme Court in Brown v. Plata upheld the release of thousands of California prisoners due to California's inability to provide constitutionally mandated levels of healthcare. In 2015, a bipartisan effort was launched by Koch family foundations, the ACLU, the Center for American Progress, Families Against Mandatory Minimums, the Coalition for Public Safety, and the MacArthur Foundation to more seriously address criminal justice reform in the United States. The Kochs and their partners are combatting the systemic overcriminalization and overincarceration of citizens from primarily low-income and minority communities. The group of reformers is working to reduce recidivism rates and diminish barriers faced by rehabilitated persons seeking new employment in the work force. In addition they have a goal in ending Asset forfeiture practices since law enforcement often deprives individuals of the majority of their private property. Decarceration in the United States includes overlapping reformist and abolitionist strategies, from "front door" options such as sentencing reform, decriminalization, diversion and mental health treatment to "back door" approaches, exemplified by parole reform and early release into community supervision programs, amnesty for inmates convicted of non-violent offenses and imposition of prison capacity limits. While reforms focus on incremental changes, abolitionist approaches include budget reallocations, prison closures and restorative and transformative justice programs that challenge incarceration as an effective deterrent and necessary means of incapacitation. Abolitionists support investments in familial and community mental health, affordable housing and quality education to gradually transition and jail employees to jobs in other economic sectors. Theorists Numerous theorists have written on the topic of prison reform and advocated for scientific, compassionate, and evidence-based approaches to rehabilitation. One of the most famous was Thomas Mott Osborne, former prison commander of Portsmouth Naval Prison and former warden of New York's Sing Sing prison, who himself chose to live briefly as a prisoner to better understand the prison experience. Osborne was a mentor to other renowned prison reform theorists, such as Austin MacCormick. Prisoners themselves, such as Victor Folke Nelson, have also contributed to the theories and literature on American prison reform. Theories of incarceration and reform Retribution, vengeance and retaliation This