International criticism of the conditions in U.S. prisons is nothing new. In 1842, on a tour of the United States, Charles Dickens compared the conditions at the Eastern State Penitentiary outside Philadelphia to being "buried alive." Charles Dickens, American Notes, Ch. 7 ("Philadelphia and its Solitary Prison") (1842). But of late, this criticism has taken on a new significance as defendants have sought to avoid extradition to the United States by arguing that it would drive them to suicide, in substantial part due to the brutal nature of U.S. prisons.