Michael L. Perlin, professor and director of New York Law School, wrote his book The Shame Of The States: Mental Disability And The Death Penalty and it was published in 2013. He claims that justice is not served when it comes to sentencing mentally ill criminals to the death penalty; He supports his claim by first explaining the issue of the death penalty in the United States, then by illustrating court cases in which mentally ill criminals have been executed, and finally by informing his audience of the rights that people have as U.S. citizens who serve as our protection. Perlin himself writes: “Mentally retarded people who meet the statutory requirements for criminal responsibility should be tried and punished when they commit crimes” (49). In other words, Perlin believes that executing mentally disabled inmates is the solution. By focusing on the execution of criminals, Perlin neglects the deeper issue of examining the mental health of inmates and providing treatment to them in order to ensure public safety and reduce the budget for capital punishment. State and federal courts can save money by providing appropriate treatment instead of execution. The cost of executing a mentally ill criminal can instead be used for someone who deserves it. The prisons are overflowing with inmates and the mentally ill are wearing out those cells. Mentally ill criminals should receive treatment or can be sent to separate facilities that will provide them with the proper care they need to reduce the costs of capital punishment and prevent prison from overflowing.