Some punishments of criminals are so inherently degrading and therefore disproportionate to the criminal's culpability, as to preclude them from ever being used. In some cases these are internationally recognized, such as, torture, death by painful and lingering methods and expatriation, forfeiture of citizenship. Some sentences that are not inherently cruel and unusual, in particular cases, are grossly and outrageously disproportionate to the defendant's conduct and to the crime committed. Pre-trail detention can be so long as to constitute cruel and inhumane punishment.