 The theory of the death row phenomenon may be traced to 1989, when the European Court of Human Rights agreed that poor conditions on death row in Virginia should mean that a fugitive should not be extradited to the US unless the US agreed it would not execute the fugitive should he or she be convicted.Additionally, the number of years that the fugitive would be on death row was considered problematic.The case is known as "Soering v. United Kingdom".