Michelle Alexander also argues that African Americans are controlled by racial caste systems which has existed in three different forms: slavery, Jim Crow and mass incarceration. Because of the caste system, it is difficult for African Americans to move up in the society. Not only they are not free to move up, they lack opportunity, in poverty, attend poor schools or lack of access to quality education. It is because they are controlled by laws, rules, and policies from doing it. Rebecca Carroll agrees that black men are incarcerated or under surveillance by the criminal justice system. However, the way the system works is more like a caste system than crime control. Once they are in felony and released from prison, they are still considered as felons and lose all their rights such as denial of public benefits, educational opportunity, employment and housing. Therefore, there is still ongoing discrimination against African Americans in