Solitary Confinement

Brief written August 9, 2026 from GPS Intelligence System data.

Georgia’s solitary confinement apparatus is not an aberration within the state’s prison system—it is a structural feature, layered across a three-tier segregation architecture that reaches from disciplinary lockdown cells at nearly every facility to the Special Management Unit (SMU) at the Georgia Diagnostic and Classification State Prison (GDCP). The U.S. Department of Justice, in its October 2024 statewide findings report, concluded that “GDC fails to control violence even in its segregated housing units and exposes incarcerated persons to an unreasonable risk of harm due to its inappropriate use of segregated housing.” The DOJ’s parallel investigation into restrictive housing, launched in April 2024, has not yet produced public findings, but the evidence already assembled by Georgia Prisoners’ Speak (GPS), the federal courts, and independent experts paints a picture of prolonged isolation so severe that a court-appointed expert called it “one of the harshest and most draconian” solitary confinement facilities he had seen in decades. Within a broader custody environment where GPS has tracked 1,860 deaths since 2020, the isolation units have become a site of concentrated lethality—deaths from dehydration, suicide, and neglect that the state itself has often failed to prevent, and sometimes actively concealed.

The Architecture of Isolation: Georgia’s Tier System and the SMU

The Georgia Department of Corrections administers a three-tier segregation regime. Tier I, the least restrictive, houses inmates under heightened supervision in dedicated close-security facilities. Tier II, described by GDC’s own fact sheet as the placement for offenders who have engaged in serious violence, escape attempts, or repeated weapons violations, confines individuals to single-occupancy cells in facilities such as Hancock, Hays, Macon, Smith, Telfair, Valdosta, and Ware State Prisons. Even at this level, GPS reporting documented that residents were confined in cells “smaller than the average parking space,” with as little as five hours per week out of cell, no outside light, and food-port flaps frequently locked. The Supreme Court’s observation in Wilkinson v. Austin that supermax conditions create an “atypical and significant hardship” underlying a liberty interest applies with force to the Tier II experience.

At the apex sits Tier III—the Special Management Unit at GDCP. GDC describes its mission as rehabilitating “close security offenders back into general population prisons through structure, programming, incentives, and education.” The reality, documented in federal court and by independent expert Dr. Craig Haney, is starkly different. As of 2017, most SMU prisoners were confined nearly 24 hours a day in cells measuring roughly six by nine feet, with solid metal doors, no exterior light, and a permeating stench of feces from in-cell showers. Haney, who inspected the unit in October 2017, found “a man who had been locked for months inside a pitch-black cell; and another man, naked and psychotic, whose cell was covered in blood.” He concluded that some prisoners’ psychological harm “may be irreversible and even fatal.”

The SMU’s population reflected the system’s disregard for mental health. Of approximately 180 prisoners held there at the time, 70—nearly 39 percent—were designated mentally ill. A full 78 percent of the unit’s residents had been confined for more than two years; 44 percent had exceeded four years. Timothy Gumm, the lead plaintiff in the litigation that would eventually bear his name, spent seven and a half continuous years in the SMU, with 14 separate recommendations that he be transferred out repeatedly ignored. Others, including Robert Watkins and Johnny Mack Brown, served eight to ten years. Such durations far exceed not only clinical warnings but also the international threshold for torture.

Gumm v. Ford: The Settlement That Was Never Honored

Gumm’s case began in 2015 as a handwritten pro se complaint filed from isolation. Appointed counsel from the Southern Center for Human Rights and Kilpatrick Townsend & Stockton LLP eventually secured a landmark settlement in May 2019. The agreement imposed a general 24-month cap on SMU confinement; required a minimum of three hours of daily out-of-cell time in common areas, plus one hour of outdoor recreation; mandated mental health evaluations before and during placement; prohibited housing anyone classified at Mental Health Level III or above in the SMU; and called for access to programming, educational tablets, and adequate nutrition. The district court, in its preliminary approval order, found that the settlement was “necessary to prevent violations of the inmates’ constitutional rights” and “narrowly tailored” to correct those violations.

Within a few years, that settlement had collapsed. In an April 2024 contempt order running 100 pages, Chief Judge Marc T. Treadwell found that GDC had been “running a four-corner offense” with “no desire or intention to comply.” Documentation submitted to demonstrate compliance was found “not only insufficient but also unreliable”—in short, falsified. Testimony from six prisoners revealed that people were still being placed naked or near-naked in “strip cells” upon arrival, held in cells where toilets were broken and filled with prior occupants’ waste, and denied shower access, clothing, and mattresses for days in freezing temperatures. GDC’s attorney did not refute the accounts. The court responded by appointing an independent monitor at GDC’s expense, imposing daily fines of $2,500 for a six-month period, and extending the settlement agreement indefinitely.

Lethal Isolation: Deaths in Segregated Housing

The physical danger of Georgia’s segregation units has been underscored by a series of deaths that the DOJ explicitly cited as evidence of deliberate indifference. In February 2023, an incarcerated man at Calhoun State Prison was found dead in his restrictive-housing cell, wrapped in mattress padding and rigid, having been dead for several hours. Staff had shut off the water supply to his cell, closed the food-port flap, and delivered no meals for two days. The coroner ruled the cause of death as dehydration with renal failure. At Smith State Prison in April 2023, another man was discovered strangled to death by his roommate in a segregated housing unit, his body badly decomposed after lying undiscovered for more than two days.

Women in Georgia’s segregation units have been similarly vulnerable. GPS’s mental health reporting documented the case of Sheqweetta Vaughan, a 32-year-old mother with postpartum depression who was found decomposing in a segregation cell at Lee Arrendale State Prison on July 9, 2025. The cell temperature was in the 90s with minimal ventilation; a neighboring prisoner reported that Vaughan had called for medical help more than 28 hours before discovery, contradicting the required 30-minute welfare checks. A pathologist stated that the state of decomposition was inconsistent with those checks having occurred. The GBI could not determine cause or manner of death. And at Smith State Prison, an inmate confined for nearly three days in a shower stall measuring 3.75 feet by 6.75 feet—with no mattress, toilet, ventilation, heat, or water—hanged himself.

The intersection of isolation and mental health crisis has repeatedly produced suicide. GPS identified multiple cases in which prisoners died by hanging while in segregation, including Justin Waymon Hollingsworth at Rogers State Prison in June 2025, Miguel Angel Duran at Central State Prison in March 2026, and Denecia Nichelle Randall at Pulaski State Prison later that same month. A 2024 Smith State Prison suicide occurred in a makeshift isolation cell that the corrections industry has long recognized as drastically increasing suicide risk. Research synthesized by the Fourth Circuit in Porter v. Clarke showed that “not a single study of solitary confinement lasting more than 10 days failed to result in negative psychological effects,” and that roughly half of all prison suicides occur among the small fraction of the population held in isolation.

The Unambiguous Science: Prolonged Isolation Is Torture

This is not a new discovery. In 1890, the U.S. Supreme Court in In re Medley recognized that solitary confinement caused prisoners to fall into a “semi-fatuous condition” or become “violently insane.” More than a century later, the scientific consensus is even firmer. Dr. Stuart Grassian identified a specific psychiatric syndrome from prolonged isolation—hypersensitivity, panic, hallucinations, paranoia, and impulse control loss—that can become permanent. Dr. Craig Haney’s studies of prisoners in isolation found that 91 percent reported anxiety, 86 percent oversensitivity to stimuli, 77 percent chronic depression, and 70 percent an impending nervous breakdown. A 2025 meta-analysis published in PLOS One, synthesizing data from 171,300 inmates, confirmed significantly greater psychological distress and psychiatric symptoms among those in disciplinary confinement. And the American Psychiatric Association’s formal position is that prolonged segregation of people with serious mental illness “should be avoided” because the harm is severe.

International standards are clear. The United Nations Mandela Rules, adopted in 2015, define solitary confinement as 22 or more hours per day without meaningful human contact, prohibit indefinite solitary, and treat any placement beyond 15 consecutive days as “prolonged solitary confinement”—a category that UN Special Rapporteurs Juan E. Méndez and Nils Melzer have both classified as torture or cruel, inhuman, or degrading treatment. GDC’s own SOP-defined Tier III program, with a 13-month minimum phased structure (SOP 209.09), and the general 24-month SMU cap imposed by the Gumm settlement, exceed that 15-day threshold by orders of magnitude. Even the 90-day review cycle for Tier II confinement is exponentially beyond what international law permits.

Fragmented Law and the Racial Disparities at the Core

Yet in the Eleventh Circuit, which encompasses Georgia, there is no published appellate decision holding that prolonged solitary confinement of any duration, for any population, violates the Eighth Amendment. While the Third Circuit has recognized a clearly established right against prolonged solitary for people with serious mental illness in Williams v. Secretary Pennsylvania DOC, and the Fourth Circuit struck down long-term death row isolation in Porter v. Clarke, the Eleventh Circuit remains silent. The open question of whether prolonged isolation of non-mentally-ill prisoners is per se unconstitutional has never been resolved in this jurisdiction. And the Fifth Circuit’s ruling in Hope v. Harris—holding that solitary “does not violate the Eighth Amendment no matter how long it is imposed for”—was allowed to stand when the Supreme Court denied certiorari in 2023, despite the petitioner having endured 27 years of continuous solitary in a 54-square-foot cell with a single personal phone call since 1994.

The burdens of this legal vacuum fall with predictable racial weight. Federal Bureau of Prisons data from 2022 showed Black individuals constituted 38 percent of the total population but 59 percent of Special Management Unit placements. For women, the Liman Center documented that Black women comprised 42 percent of women in solitary while making up only 22 percent of the total female prison population. Within Georgia, the SMU’s heavily Black demographics mirror those of the larger close-security population and reflect the broader structural racism that channels people of color into longer, harsher confinement.

Georgia in a Reform-Minded Nation—and the Path Forward

Other states have moved decisively. New York’s HALT Solitary Confinement Act, in effect since 2022, caps solitary at 15 consecutive days, mandates four hours of daily out-of-cell programming, and prohibits the practice for people under 21, over 55, pregnant, or with serious mental illness. Oregon and North Dakota achieved reductions in solitary confinement of 55.7 percent and 74.28 percent, respectively, without increases in violence. Four states—Colorado, Delaware, North Dakota, and Vermont—have eliminated restrictive housing entirely. Vera’s Restoring Promise program in South Carolina achieved an 83 percent reduction in the odds of restrictive-housing stays and a 73 percent reduction in the odds of violent incidents. And the Pennsylvania settlement in Disability Rights Network v. Wetzel requires evaluation of all incoming prisoners for serious mental illness, caps any restrictive-housing placement of those identified at 30 days, and mandates 20 hours per week out of cell.

Georgia has none of these protections. The Brennan Center identifies the state as lacking independent prison oversight entirely, and the Governor’s race has surfaced pledges from candidates to strengthen reentry and mental health services, but systemic solitary reform remains absent from the legislative agenda. The DOJ’s restrictive-housing findings, believed to be forthcoming as of mid-2026, are the next major pressure point. In the meantime, GPS records show a statewide pattern of due process violations alleged across eight facilities—including GDCP, Augusta State Medical Prison, and Calhoun State Prison—and mental health crises left unattended in restrictive-housing units at three facilities, including the medical prison itself. The gap between the constitutionally minimal protections that the Gumm settlement was supposed to guarantee and the reality inside Georgia’s isolation cells remains a chasm that the federal courts have identified but not yet closed.

Sources: This analysis draws on GPS’s own investigative reports on solitary confinement and mental health in Georgia prisons; the U.S. Department of Justice’s October 2024 findings report; federal court records from Gumm v. Ford, Williams v. Secretary Pennsylvania DOC, Porter v. Clarke, and Hope v. Harris; expert reports and peer-reviewed research by Dr. Craig Haney, Dr. Stuart Grassian, and others; the United Nations Mandela Rules and UN Special Rapporteur statements; state reform legislation and settlement agreements from New York, Pennsylvania, Oregon, North Dakota, and South Carolina; data from the Association of State Correctional Administrators-Liman Center Nationwide Survey; and GPS’s own signals database of due process and mental health crisis reports across Georgia facilities.