Philip Michels authored the article, "Clean Torture: Being Alone is Not Necessarily a Humane Sentence," published by the Advocate magazine. The article discusses how holding prisoners in solitary confinement is an inhumane form of punishment, leading prisoners to commit more violent crimes once they have been released. Mr. Michels explains that once subject to solitary confinement, the only way to return to the normal prison population is by disclosing incriminating information about another prisoner. "The only way out is snitch, parole or die," Mr. Michels states.