the penal system has been cited as failing to protect juveniles in custody. in the uk, “twenty-nine children have died in penal custody in 1990. some 41% of the children in custody were officially designated as being vulnerable.” this is attributed to the fact that isolation and physical restraint are being used as the first response to punish them for simple rule infractions. moreover, frances crook argues that these punitive policies not only violate their basic rights, but also leave the children mentally unstable and left with illnesses that are often ignored. overall, the solitary confinement of youth is considered to be counterproductive because the “restrictive environment…and intense regulation of children” aggravates them, instead of addressing the issue of rehabilitation.