A prison sentence is usually described by its length. For a small number of the best-known prisoners in the English-speaking world and beyond, the more telling detail is where the sentence is served, who is kept away from them, and who decided it. Corrections officials, judges and parole boards have spent decades answering one question about men and women whose names are known to every other prisoner: what do you do with someone who is in danger because of what he is said to have done, and who may also be dangerous to others? The answers have been protective custody, administrative segregation, a transfer across a province or a state, a police cell where a court sent a man "provisionally" and left him for a quarter of a century, and, in one nineteenth-century case, a night in a jail under a false name.
What follows tracks those moves. Some of the people named below were convicted of serial murder. Others were never convicted of anything, and the wording below follows the court records: convicted, never tried, acquitted. Each section says what the move was and who ordered it, as far as the published record allows.
Andres Filomeno Mendoza Celis was 72 when he was arrested in Atizapan de Zaragoza, a municipality in the State of Mexico on the northwest edge of Mexico City, in May 2021. He had been a butcher, and he had once been president of his neighborhood’s residents' association. Investigators estimated that up to 19 people were connected to the case, while his own reported statements and some press reports gave 30 or more, a figure never tested in court.
What courts have decided is narrower. Between March 2022 and February 2024 he was convicted in eight separate cases of femicide and related offenses. The first judgment, reported on March 19, 2022, was life imprisonment for the femicide of Reyna Gonzalez Amador, 34, with a fine of 448,100 pesos and 1.34 million pesos in reparation. Later judgments added 55 years for another woman, 92 years in a case involving a woman and a child, four more terms of 55 years in 2023, and an eighth term of 55 years on February 8, 2024, for a woman identified as B.S.O., in a case dating to April 2012. The State of Mexico prosecutor’s office reported each sentence as it came; fines and reparation orders accompanied them.
He was first held at the Barrientos prison in Tlalnepantla. In July 2021, two months after his arrest, he was moved to the prison at Tenango del Valle. The reason, adn Noticias reported, was his own safety: he had received threats, and the proceedings against him continued from the new prison. The official who ordered the move has not been named. The decision, in other words, was an administrative one, taken before any court had convicted him of anything.
Tenango del Valle has been his address ever since, with one interruption. In August 2025 he was taken to the Adolfo Lopez Mateos hospital in Toluca with respiratory complications. TV Azteca, citing sources close to the case, described his condition as serious and said no detailed diagnosis was released. He was discharged almost two months later and returned to Tenango del Valle on October 1, 2025. As of May 2026, TV Azteca reported, he was serving his sentences there.
In the autumn of 1972 the Boston area was following a run of killings of young women that became known as the hitchhike murders. The Harvard Crimson, reporting on an arraignment in 1973, described the case before the court as one of eight young women slain in the Boston area since the previous summer. Anthony J. Jackson, who was 33 and lived in Dorchester, was arrested in Cambridge on December 26, 1972, on charges that included armed assault with intent to murder. The courts then spent more than a decade on what followed.
The Supreme Judicial Court of Massachusetts affirmed his convictions in 1978, 1981, 1983 and 1984. He was convicted of murder in the first degree of Ruth A. Hamilton, 23, with kidnapping, rape and unarmed robbery, on December 22, 1976; of murder in the first degree of Ellen Ann Reich, 19, in 1978; and of the murder and kidnapping of Damaris Synge Gillispie, 22, in 1978. He had also been convicted in June 1976 of armed assault with intent to murder and of unlawful carrying of a firearm, arising from the Cambridge case. In 1977 a Plymouth County jury acquitted him of the 1972 rape and murder of a Cambridge woman. The Hamilton sentence was life imprisonment without parole, with further terms to follow, and the Reich sentence of life imprisonment was to be served after his other sentences.
His time inside is the part of the record that matters here. In the summer of 1976, according to the court’s later account, about eight inmates of the Massachusetts Correctional Institution at Cedar Junction came into his cell and assaulted him. In 1983 the Supreme Judicial Court upheld a decision by the state’s corrections commissioner to move him from a medium security facility to a maximum security one, and the court recorded that Jackson feared for his safety if he were sent back to Cedar Junction. Here the decision-maker is on the record: the commissioner chose the facility, and Jackson fought the choice in court, on the argument that the prison he would be sent to was a place where he had already been hurt.
A second case, decided in 1985, shows how little the prison assault changed his legal position. Jackson had sued over a newspaper article published in May 1977. In Jackson v. Longcope, decided April 17, 1985, the Supreme Judicial Court assumed for the purpose of the appeal that the article was libelous and then held that he was libel-proof. By May 1977, the court said, his record, which included a murder conviction, a rape conviction and the convictions from the Cambridge case, meant that his reputation could not have been further harmed, and the most he could have hoped for at trial was nominal damages. The court added that the rule applies only where that is clear as a matter of law. Recounting the 1976 assault, it wrote: "Even in that segment of society, Jackson appears to have had a reputation not universally respected." He was serving a life sentence at the time of the ruling.
No other case here runs as long, with so little decided, as that of Jose Dorancel Vargas Gomez, who is usually written Dorangel Vargas. He has been held in a police jail in San Cristobal, the capital of Venezuela’s Tachira state, since February 1999. He has never been tried and never been sentenced.
He was born on May 14, 1957, in El Vigia, in Merida state, and grew up on a farm in a poor family. In 1995 he was accused in the death of Cruz Baltazar Moreno, a man who slept under the same bridge. He was not tried; he was committed to the Instituto de Rehabilitacion Psiquiatrica de Peribeca, and he was released after about two years. In February 1999 he was arrested at Tariba, in the Cardenas municipality of Tachira, where he was living in a shack, on February 12, 1999. Police said he admitted killing several men around Tariba between late 1998 and early 1999; the press reported a confession to about ten, and a 2017 feature put the figure at about a dozen. There is no court finding on any of it. Psychiatrists diagnosed paranoid schizophrenia, and he was declared not criminally responsible. A former Tachira judge describes the result as a ruling with a security measure but no conviction.
He was not sent to an ordinary prison. La Nacion, the San Cristobal newspaper, reported in 2016 that he had been sent "provisionalmente," under a court measure, to the Cuartel de Prisiones of the Tachira state police, because a mentally ill man with his history was judged to be in grave danger in an ordinary prison. Infobae reported in 2017 that he was kept in isolation in a facility of the state’s Directorate of Security and Public Order, because he was considered a person of "peculiar peligrosidad," particular dangerousness. The two reasons sit next to each other in the coverage: his safety and other people’s.
The provisional placement became permanent. A transfer to the Barbula psychiatric hospital in Carabobo state was arranged and failed, and he was returned to the Politachira jail in 2002. In 2010, according to Infobae and El Diario, a court ruling held that the police jail was "no era el mejor lugar," not the best place, for a man with his diagnosis. Both outlets report that the same ruling concluded that he should stay where he was, for his own safety and that of others. The court and the judge have not been named. In 2020, La Nacion and El Diario reported that he was held alone, on a different floor from the rest of the detainees. In October 2020 El Diario checked reports that he had been released; they were false, and the Politachira director denied them.
An episode in October 2016 shows how contested the jail’s account of him is. A riot at Politachira produced allegations, reported by El Correo del Orinoco, that detainees had been harmed in a way that relatives linked to Vargas. Relatives of detainees claimed he had taken part in what was done to two men. Infobae reported that police considered whether he had been involved and that he denied it. In an interview with La Nacion in November 2016, Vargas said he had been locked in his cell during the riot and was later moved to another cell with many other people. A former director of the jail, Berro, told La Nacion in 2020 that Vargas was not involved and that his name did not appear in the case file on the riot. The 2024 reports that relay the findings of the nongovernmental group Una Ventana a la Libertad say the claims were denied and that he was held in his cell throughout.
The same former directors describe a man who gave them little trouble. Another director, Torres, said in 2017, according to the 2024 reports, that Vargas helped clean the facility and was receiving treatment. Berro described him as calm and cooperative and said he delivered correspondence to other detainees; he told La Nacion that Vargas sometimes served as an orderly and was "realmente no es agresivo," not really aggressive. Neither former director reported violent or threatening behavior. Berro proposed that doctors from the acute-patient unit of the Hospital Central examine him regularly, that his medicine be guaranteed, and that close relatives be located who could take custody of him. In 2024 he was taking medication prescribed by a specialist and was visited by a relative.
The October 2024 reports gave the length of the arrangement as 25 years. The arrangement is a safety measure that has outlived its label: a "provisional" cell, for a man no court has convicted, in a jail where he has now spent more than a quarter of a century.
A Wisconsin jury rejected Jeffrey Dahmer’s insanity defense on fifteen counts on February 15, 1992, and he received fifteen consecutive life terms, with a sixteenth life term in Ohio that May. On November 28, 1994, aged 34, he was killed by another prisoner at Columbia Correctional Institution in Portage, Wisconsin.
Joel Rifkin, an unemployed landscaper from East Meadow on Long Island, was arrested on June 28, 1993, in Nassau County. He was 34. New York State Police credit him with a confession to 17 killings of women between 1989 and 1993. Nassau County jurors convicted him of murder in the second degree of Tiffany Bresciani, 22, with reckless endangerment in the first degree, on May 9, 1994, and rejected his insanity defense. He pleaded guilty in Suffolk County in 1995, receiving two consecutive terms of 25 years to life, a sentence the Spokesman-Review summarized as 50 years to life. On December 1, 1995, United Press International reported that he pleaded guilty to three Brooklyn killings. News reports give his total as nine murder convictions and his consecutive sentences as totaling 203 years to life.
His years in custody are less documented than his trials. The Long Island Press reported in 2011 that he had been moved to the maximum-security Clinton Correctional Facility in Dannemora, near the Canadian border, after a fistfight with Colin Ferguson, the man convicted in the Long Island Rail Road case; the two were reportedly arguing over which of them had more victims. That is a move made because of a quarrel between two prisoners rather than a threat, and it is a reminder that the corrections system’s risk calculations about high-profile inmates cut in two directions. Reports in 2024 and 2026 placed him at Clinton, serving his sentence.
Paul Bernardo was convicted on September 1, 1995, of the first-degree murders of two Ontario schoolgirls, Leslie Mahaffy, 14, of Burlington, and Kristen French, 15, of St. Catharines, with other charges. A Toronto jury convicted him on all nine counts he faced, and on November 3, 1995, he was declared a dangerous offender, which makes his life sentence indeterminate. He was eligible for parole after 25 years. He had been arrested on February 17, 1993, after the Centre of Forensic Sciences matched his DNA to a series of earlier crimes in Scarborough, Toronto. Justice Archie Campbell, who reviewed the police work for the Ontario government, concluded that Toronto police had interviewed Bernardo and taken a blood sample in November 1990, and that the sample sat untested for more than two years. Ontario spent the next several years rebuilding its approach to serial offenders: a ViCLAS center for linking violent crimes opened in December 1996, reporting to it became mandatory in February 1997, and the province set aside 25 million dollars over five years.
His wife at the time, Karla Homolka, agreed in May 1993 to testify against him and plead guilty to two counts of manslaughter. On July 6, 1993, she received two concurrent sentences of 12 years. Critics called it a "deal with the devil," and a petition with more than 300,000 names was delivered to the Ontario legislature. A 1996 inquiry report by Galligan concluded that on what the Crown knew in 1993 it "had absolutely no choice" if it wanted to be sure of convicting Bernardo.
Bernardo spent 18 years at Kingston Penitentiary, a maximum-security prison, and moved to Millhaven Institution, near Bath, Ontario, when Kingston closed in 2013. He has spent most of his time there in protective custody or solitary confinement. At his 2021 parole hearing he said he had gone more than 10,000 days without meaningful human contact. In 2015, CBC News reported, he applied for day parole in the Toronto area, three years before his eligibility date, as the law allowed. A weapon charge arose from an item discovered in his maximum-security cell; on October 5, 2018, the Crown withdrew it, saying there was no reasonable prospect of conviction. His lawyer, Fergus (Chip) O’Connor, suggested someone else had placed it there. Parole was denied on October 17, 2018, on June 22, 2021, and on November 26, 2024.
On May 29, 2023, Correctional Service of Canada moved him from Millhaven to La Macaza Institution in Quebec, a medium-security prison. The move provoked public anger. A Correctional Service review published on July 20, 2023, called the decision "sound." A parole hearing set for October 20, 2026, was postponed to January 2027, CP24 reported on September 21, 2026.
William Hare was never tried for any crime. In the winter of 1828 the Lord Advocate of Scotland, Sir William Rae, chose him as the witness who would let the Crown convict William Burke, and offered him immunity. Burke, in confessions made after his conviction, said there had been sixteen killings in the West Port of Edinburgh in 1828 and that his only accomplice was Hare; the dead were supplied to the private anatomy school of Robert Knox. The University of Edinburgh’s medical school and its Anatomical Museum describe Burke and Hare together as having killed at least 16 people. No court ever ruled on Hare’s part.
According to the National Library of Scotland, Hare, his wife Margaret, Burke and Helen McDougal were detained on November 3, 1828; the University of Edinburgh gives November 1 for Burke and the next day for Hare. Rae decided that one of the four would have to give evidence against the others, and chose Hare, who was to be "turned King’s evidence" on the offer of immunity if his evidence led to the prosecution of Burke and McDougal. Margaret Hare could not be compelled to testify against her husband. The Faculty of Advocates, in a 2019 note, says that because the Crown might not otherwise have proved its case, both Hare and his wife were invited to turn King’s evidence. Hare gave evidence at the trial on December 24 and 25, 1828. Burke was convicted and executed on January 28, 1829.
The National Library of Scotland says Hare was held in prison for his own protection until his release on February 5, 1829. The Faculty of Advocates notes the disquiet in Edinburgh when a man who had told of the killings was freed, and a private prosecution was brought against him for the death of James Wilson. It failed. A correspondent writing in History Ireland described Hare as having received immunity for murders he might have committed while admitting to none of them, and placed his flight after that prosecution collapsed.
Hare tried to return to Ireland. A penny broadside sold in 1829, taken from the Edinburgh Evening Courant of February 9, reported that he was on his way when he reached Dumfries, where a crowd threatened his life. He took shelter in the Dumfries jail under the name "Mr Black," was smuggled out of the town under police guard, and was left on the way to Carlisle. A second broadside, "Riot at Dumfries! Hares Arrival," called him one of the West Port murderers. The Gazetteer for Scotland says the crowd broke into the room he had taken. All the Year Round, in 1867, described him as besieged in an inn by a crowd calling for "the murderer," which followed him to the jail and threatened to burn its door, and said he later got away from a port in Cumberland and reached London. History Scotland says the crowd forced him out of Dumfries. The History Ireland correspondent put the last reliable sighting of him on the way to Carlisle on February 7, 1829.
What happened afterward is guesswork. A broadside printed in 1829 claimed that Helen McDougal and Hare had both been killed by a mob; the National Library of Scotland’s note on the sheet says Hare in fact survived and apparently died in obscurity in London around 1860. Neither woman was convicted of anything. The Library says McDougal left Edinburgh two days after the trial and that what became of her is not known, and that Margaret Hare went to Ireland and nothing is known of her later life. All the Year Round wrote that she was pelted with snowballs, mud and stones, was nearly killed at Glasgow, and escaped to Belfast.
Knox was not called as a witness and was never charged. A crowd hung an effigy of him outside his residence on February 12, 1829, according to the Library, and he was caricatured and gradually shut out of the city’s academic circles. The University of Edinburgh says he later moved to London and died in Hackney in 1862.
Mark Alan Smith, born June 27, 1949, according to the Illinois Prisoner Review Board’s file, has been in prison since 1970. He was arrested on May 28, 1970. He is serving an Illinois sentence that adds up to 448 to 500 years, imposed after guilty pleas, for the murders of three young women in the Chicago area in 1970, one of them a 17-year-old, for whom the conviction is murder, with other charges. A life sentence imposed in Arkansas on March 18, 1971, after a bench trial for the murder of a 20-year-old woman in December 1969, is to be served if Illinois ever releases him. He has also been suspected of killings of young women in West Germany while serving in the U.S. Army. No prosecution followed; newspaper reports put his admission at eight, while the board’s 2014 file said he was suspected of three to eight and that he himself put the number at two.
The board’s file shows a prisoner whose custody level has moved with his conduct. His record, as summarized for the board in 2014, showed 27 disciplinary reports between 1971 and 1977 and 14 between 1985 and 2008, the last a major ticket in 2008 for striking another prisoner. In 2014 he was held in protective custody at maximum security and rated a high escape risk. By 2024 the board noted that he held an A grade for lack of disciplinary actions, and he was in a medium security prison with a moderate escape risk designation. The Prisoner Review Board’s July 2024 hearings schedule put him at Danville Correctional Center. The board’s 2014 interviewer wrote that he had been diagnosed as a sociopath, and a psychiatrist’s report quoted in the 2019 minutes said that whenever he felt threatened he reacted violently.
The parole record is a chronicle of refusals. At his interview at Pontiac on July 22, 2014, he told the interviewer, in words the minutes record, "why bother I am not going to ever be paroled," said he was no longer the young, stupid, unconscionable person he had been, and accepted that the change had come too late. He said he had no parole plans and no family contact, and asked to be transferred to Arkansas. On August 28, 2014, the board voted 14 to 0 to deny parole and 14 to 0 for a five-year set. The board’s file that year gave his projected release date as July 13, 2220.
In 2019 he was interviewed by teleconference at Danville. Asked why he had killed the women, he said he did not know. A Cook County assistant state’s attorney, Sara Whitecotton, spoke against release, and the board denied parole on September 26, 2019, by 13 to 0. McHenry County Assistant State’s Attorney Michael Combs told the Northwest Herald that Smith deserved to die in prison. On August 29, 2024, the board again denied parole unanimously, with a five-year set. A Patch summary that year said he had been convicted of or confessed to killing nine other women in the United States and Germany; that figure is not a count of proven killings, because the court record supports four murder convictions.
The decisions in these cases were made by different hands: a state prison service in Mexico acting on threats, a Massachusetts corrections commissioner whose choice a court reviewed, a Venezuelan court that sent a mentally ill man to a police cell, Canadian officials who moved a prisoner and then published a review of their own judgment, Illinois classification staff, and a Scottish prison in 1829. The stated reasons differ. In some the safety of the prisoner is named outright. In others it is the safety of everyone else, or a fight between two inmates, or one prisoner’s fear of a particular cell block.
The durations differ as well. The Venezuelan cell described as provisional in 1999 was still in use in 2024. Bernardo told a parole board in 2021 that he had gone more than 10,000 days without meaningful human contact. Smith was in protective custody at maximum security in 2014 and in medium security with an A conduct grade in 2024. Hare’s protective detention lasted from November 1828 to February 5, 1829, and the danger he faced did not end at the jail door: it was waiting for him at Dumfries.
• 1828: Killings in Edinburgh’s West Port later attributed to William Burke and William Hare; Burke’s confessions name Hare as his only accomplice.
• November 1 to 3, 1828: Burke and Hare arrested (dates differ between the National Library of Scotland and the University of Edinburgh).
• December 24 to 25, 1828: Hare gives evidence for the Crown at the trial of Burke and Helen McDougal.
• January 28, 1829: Burke executed.
• February 5, 1829: Hare released from prison after being held for his own protection.
• February 7 to 9, 1829: A crowd threatens Hare at Dumfries; he is taken out of the town under guard.
• February 12, 1829: A crowd hangs an effigy of Robert Knox.
• December 3, 1969 to May 27, 1970: Dates of the killings for which Mark Alan Smith is convicted.
• May 28, 1970: Smith arrested.
• March 18, 1971: Smith receives a life sentence in Arkansas.
• 1972: Boston-area killings of young women.
• December 26, 1972: Anthony J. Jackson arrested in Cambridge.
• 1976: Jackson assaulted by inmates at Cedar Junction; first conviction in the Hamilton case December 22, 1976.
• 1983: Supreme Judicial Court upholds the corrections commissioner’s transfer of Jackson to a maximum security facility.
• April 17, 1985: Jackson v. Longcope decided.
• 1992: Jeffrey Dahmer found sane February 15; Ohio plea in May.
• February 17, 1993: Paul Bernardo arrested.
• June 28, 1993: Joel Rifkin arrested in Nassau County.
• May 9, 1994: Rifkin convicted by a Nassau County jury.
• November 28, 1994: Dahmer killed in prison.
• 1995: Rifkin pleads guilty in Suffolk County (August) and Kings County (December 1).
• September 1, 1995: Bernardo convicted; declared a dangerous offender November 3, 1995.
• 1995 to 1999: (Vargas) 1995 accused in a death, committed to a psychiatric institute; February 1999 arrested at Tariba and sent to the Tachira state police jail.
• 2002: Vargas returned to the Politachira jail after a failed psychiatric transfer.
• 2010: A court ruling finds the police jail "not the best place" for Vargas but concludes he should stay.
• 2013: Bernardo moved from Kingston to Millhaven.
• August 28, 2014: Illinois board denies Smith parole, 14 to 0.
• September 26, 2019: Board denies Smith parole again, 13 to 0.
• May 2021: Andres Filomeno Mendoza Celis arrested.
• July 2021: Mendoza Celis moved to Tenango del Valle after threats.
• March 2022 to February 2024: Eight convictions of Mendoza Celis.
• May 29, 2023: Bernardo moved to La Macaza Institution; review called the move "sound" on July 20, 2023.
• August 29, 2024: Board denies Smith parole unanimously.
• November 26, 2024: Bernardo denied parole for a third time.
• October 1, 2025: Mendoza Celis returned to Tenango del Valle after hospital treatment.
• September 21, 2026: Bernardo’s October hearing reported postponed to January 2027.