harm or deliberate indifference to it "could be plausibly inferred from a prospective cellmate's conviction of sexual offenses coupled with the alleged vulnerability of a transgender inmate transitioning to a woman in a men's prison". V-coding A 2018 report from the Indiana Maurer University School of Law found that it was common for trans women placed in men's prisons to be assigned to cells with aggressive cisgender male cellmates as both a reward and a means of placation for said cellmates, so as to maintain social control and to, as one inmate described it, "keep the violence rate down". Trans women used in this manner are often raped daily. This process is known as "V-coding", and has been described as so common that it is effectively "a central part of a trans woman's sentence". The report also found it common for correctional officers to publicly strip search trans women inmates, before putting their bodies on display for not only the other correctional officers, but for the other prisoners. Trans women in this situation are sometimes made to dance, present, or masturbate at the CO's discretion. The prisoners serving as customers for these women are informally referred to as "husbands". Trans women who physically resist the customer's advances are often criminally charged with assault and placed in solitary confinement, the assault charge then being used to extend the woman's prison stay and deny her parole. Immigration In 2000, the US Ninth Circuit Court of Appeals concluded that "gay men with female sexual identities [sic] in Mexico constitute a 'particular social group that was persecuted and was entitled to asylum in the US (Hernandez-Montiel v. INS). Since then, several cases have reinforced and clarified the decision. Morales v. Gonzales (2007) is the only published decision in asylum law that uses "male-to-female transsexual" instead of "gay man with female sexual identity". An immigration judge stated that, under Hernandez-Montiel, Morales would have been eligible for asylum (if not for her criminal conviction). Critics have argued that allowing transgender people to apply for asylum "would invite a flood of people who could claim a 'well-founded fear' of persecution". Precise numbers are unknown, but Immigration Equality, a nonprofit for LGBT immigrants, estimates hundreds of cases. The United States has no process for accepting visa requests for third gender citizens from other countries. In 2015, trans HIV activist Amruta Alpesh Soni's request for a visa was delayed