A bird flies over barbed wire on top of fences at the Richard J. Donovan Correctional Facility in San Diego, California, U.S., on Wednesday, March 26, 2014. California is under a federal court order to lower the population of its prisons to 137.5 percent of their designed capacity after the U.S. Supreme Court upheld a ruling that inmate health care was so bad it amounted to cruel and unusual punishment. Photographer: Sam Hodgson/Bloomberg via Getty Images
