Madrid v. Gomez exposed in detail of the mental deterioration in prisoners of and of abusive behavior by prison officers. Simon argues that most importantly, the case was the first to correctly identify the constitutional significance of mass incarceration’s failure to reckon with biological and psychological consequences of its practices and the consequent threat to human dignity. In other words, not only does Supermax incarceration legally take away a prisoners liberty, but it also denies them pure human existence and biological existence.