In a return to the old-fashioned punishment of public humiliation, defendant Shawn Gementera (convicted of mail theft) was sentenced to standing outside a post office wearing a sign that read: "I stole mail. This is my punishment."

In US v. Gementera, the Ninth Circuit did not find this sandwich-board sanction to exceed the bounds of "civilized standards." To paraphrase the holding: Given the gravity of the admitted offense, wearing the sign would be more effective and less odious than going to jail.

A second case from the Ninth Circuit dealing with public humiliation, Demerey v. Arpaio involves a sheriff who installed several live webcams in a predetention center.

Sheriff Joe Arpaio, was quoted as saying: "We get people booked in for murder all the way down to prostitution. . . When those johns are arrested, they can wave to their wives on the camera." One such camera allegedly captured images of the toilet and surrounding area in the women's holding cell.

Upholding an preliminary injunction against the use of the streaming images, the Ninth Circuit held that the webcams are not reasonably related to a non punitive purpose.