The Second Circuit has determined that the conditions in 41-bis detention (a detention setting for mafia associates) in Italy do not amount to torture, despite including prolonged solitary confinement, limited access to counsel and family, and (at times) lack of access to medical care. The decision drew a lengthy dissent, which characterized solitary confinement as “one of the true horrors of the modern-day penal system.”
The full text of Gallina v. Wilkinson can be found here: