GPS RESEARCH LIBRARY: Holding cages and restraint in Georgia prisons ============================================================ Georgia Prisoners' Speak — gps.press Generated: 2026-11-13 14:36:07 EST Research Date: 2026-11-11 Topic: Prison conditions JSON: https://gps.press/research-data/holding-cages-and-restraint-in-georgia-prisons/?format=json SUMMARY ---------------------------------------- Use of holding cages and restraint in Georgia prisons. CASE DETAILS (19) ---------------------------------------- - [reported] Rogers State Prison: six weeks without shower or outside recreation in segregation-related conditions The DOJ findings report states one incarcerated person at Rogers State Prison reported he had gone six weeks without a shower and received no outside recreation while held in segregation-related conditions. Tags: conditions,solitary,facilities Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] Lawsuit: Ramirez placed in outdoor rec cell at 86 degrees after mental health meeting A lawsuit alleges a prison staff member brought Ramirez to an outdoor 'rec cell' around 10 a.m., after his meeting with a mental health provider, when the temperature had reached 86 degrees. Tags: conditions,mental_health,solitary,death Sources: Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024 - [reported] Hays State Prison: assaulted man held naked in suicide-watch cell without mattress or blanket The DOJ findings report states that at Hays State Prison, an incarcerated individual placed in a suicide-watch cell after being assaulted was held naked in the suicide cell with no mattress or blanket after his property had been stolen. Tags: conditions,mental_health,solitary,facilities Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] Lawsuit: nurses found Ramirez naked on concrete near vomit and excrete about 3 p.m. About 3 p.m., five on-site nurses rushed into the yard in response to an alert from security staff and found Ramirez lying naked on the concrete near his vomit and excrete, according to the lawsuit. Tags: conditions,medical,death,solitary Sources: Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024 - [reported] Rogers State Prison: people held in kiosks and shower cages up to a week when segregation cells unavailable The DOJ Civil Rights Division's findings report on Georgia prisons states that at Rogers State Prison, incarcerated individuals described being held in kiosks and shower cages for up to a week when segregation cells were unavailable, and some described having to defecate and urinate in the cages. Tags: conditions,solitary,facilities Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] Ware State Prison: nearly a year without a mattress; blocked from bathroom and defecated in pants The DOJ findings report states that at Ware State Prison, an incarcerated person reported that he had gone almost a year without a mattress, was blocked from going to the bathroom by another incarcerated person who chased him with a broom and a rock, and defecated in his pants. Tags: conditions,violence,facilities Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] SCHR: man held in E2 kiosk cage multiple days after suicidal ideation; urinated in bottles, defecated on trays The SCHR letter states one man at Valdosta State Prison reported being held in a kiosk cage in housing unit E2 for multiple days in the spring of 2025 after expressing suicidal ideation; the cage had no sink and no toilet, so he urinated in bottles and defecated on trays. Date: 2025-01-01 Tags: conditions,mental_health,solitary,facilities Sources: SCHR Letter of Concern Re: Unconstitutional Conditions at VSP - [reported] SCHR: VSP F1 cell without working sink or toilet for two to three days in April 2025 The SCHR letter states that a man in housing unit F1 at Valdosta State Prison reported living in a cell with neither a working sink nor a working toilet for two to three days in April 2025, during which time he and his roommate urinated in bottles and defecated in bags. Date: 2025-01-01 Tags: conditions,facilities Sources: SCHR Letter of Concern Re: Unconstitutional Conditions at VSP - [confirmed] Taylor v. Riojas: feces packed in water faucet, inmate did not eat or drink four days Taylor v. Riojas describes the first cell as covered nearly floor to ceiling in massive amounts of feces, packed inside the water faucet, causing Taylor not to eat or drink for nearly four days. Date: 2020-11-02 Tags: conditions,legal Sources: Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener) - [reported] Juan Carlos Ramirez Bibiano death at Telfair State Prison GPB reported that Juan Carlos Ramirez Bibiano, serving time at Telfair State Prison, died on July 20, 2023, from a heart attack allegedly caused by heat exposure. Date: 2023-07-20 Tags: death,conditions,facilities Sources: A Georgia inmate died from heat exposure. Left with questions, his family is suing the state | Georgia Public Broadcasting - [confirmed] Hope v. Pelzer: Larry Hope handcuffed to hitching post about seven hours Hope v. Pelzer describes that Larry Hope was handcuffed to a hitching post for approximately seven hours, was given water only once or twice and was given no bathroom breaks during that period, and a guard kicked over a water cooler spilling water onto the ground after taunting him about his thirst. Date: 2002-06-27 Tags: legal,conditions Sources: Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener) - [reported] Ramirez lawsuit: left in outdoor recreation cage GPB reported that the lawsuit says Ramirez 'was not inside but rather outside, left in what are commonly called outdoor recreation cages.' Date: 2023-07-20 Tags: death,conditions,legal Sources: A Georgia inmate died from heat exposure. Left with questions, his family is suing the state | Georgia Public Broadcasting - [reported] Ramirez lawsuit: five hours in outdoor cell before medical attention GPB reported that per the lawsuit, Ramirez 'was left in an outdoor cell five hours before receiving medical attention' and 'was found naked and in dire physical condition,' with 'the heat index... said to have reached 105 degrees by that time.' Date: 2023-07-20 Tags: death,conditions,medical Sources: A Georgia inmate died from heat exposure. Left with questions, his family is suing the state | Georgia Public Broadcasting - [confirmed] Brooks v. Warden: shackled man forced to soil himself during three-day hospital stay after SMU riot Brooks v. Warden describes that while shackled with leg irons and maximum-security waist-chain handcuffs during a three-day hospital stay following a prison riot at the Special Management Unit, Brooks was refused permission to lower his waist-chains to use the toilet, was forced to soil his jumpsuit for the remainder of his hospital stay, and that Deputy Warden Powell and correctional officers laughed and made fun of him during this ordeal. Date: 2015-01-01 Tags: conditions,legal,solitary Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] DOJ SCI Cresson: prisoner KK restraint chair near 24 hours In its DOJ findings letter on SCI Cresson, the Civil Rights Division described an incident in which a prisoner identified as KK's total time in the restraint chair neared 24 straight hours, during which officers applied a handheld electronic body immobilization device and deployed pepper spray on his face twice while he had only one limb removed from restraints. Tags: mental_health,conditions,solitary Sources: U.S. Department of Jnstice - [confirmed] Brooks v. Warden: Brooks held in SMU at GDCP; Eighth Amendment claims against four officials Brooks v. Warden identifies Fred Dalton Brooks as incarcerated in the Special Management Unit at Georgia Diagnostic and Classification Prison in Jackson, Georgia, bringing Eighth Amendment claims against Warden Carl Humphrey, Deputy Warden William Powell, Deputy Warden June Bishop, and SMU Unit Manager James McMillan. Date: 2015-01-01 Tags: legal,solitary,facilities Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] DOJ SCI Cresson: self-harm response and six days without mattress In its DOJ findings letter on SCI Cresson, the Civil Rights Division found that Cresson responded to a prisoner's self-harm by placing him in a restraint chair for 10 and-a-half hours in the concrete observation cell, and after being released from the restraint chair, Cresson kept him in the concrete cell without a mattress wearing only a smock for six days. Tags: mental_health,conditions,solitary Sources: U.S. Department of Jnstice - [reported] Lawsuit: Georgia State Prison solitary cells infested with rats and roaches, waste accumulates A federal lawsuit filed against Georgia Department of Corrections officials alleges that in solitary confinement units at Georgia State Prison in Reidsville, cells are infested by rats and roaches and smell of urine and feces because human waste accumulates in toilets and the flush mechanism is controlled by staff. Tags: conditions,solitary,facilities,legal Sources: Solitary confinement in Georgia prison overly harsh, lawsuit alleges Please ensure Javascript is enabled for purposes of website accessibility - [reported] Lawsuit: Juan Carlos Ramirez died after five hours in Telfair cage, heat index 105 A lawsuit states that Juan Carlos Ramirez died after being left outside in a cage in the small yard of Telfair State Prison, where he was outside in the sun for about five hours with no water, ice or shade, and attorneys say the heat index that day reached 105 degrees. Tags: death,conditions,facilities,legal Sources: Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024 FINDINGS (19) ---------------------------------------- - [reported] SMU solitary confinement cell dimensions An attorney blog reports that solitary confinement cells in Georgia's Special Management Unit (SMU), at the heart of a federal contempt order, measure 7 feet by 13.5 feet and contain a toilet and mattress, with meals delivered through a slit in a solid door with a small window at the top. Date: 2024-05-01 Tags: solitary,conditions,facilities Sources: Solitary Confinement in Georgia Prisons is "Draconian": Confinement in a Prison Shower is Immoral and Unconscionable - Atlanta Injury Lawyer Blog - May 1, 2024 - [confirmed] Braggs v. Dunn: suicidal prisoners placed in unsafe crisis cells In Braggs v. Dunn, the court found that suicidal prisoners in ADOC are often placed in unsafe environments both because of the shortage of crisis cells and because many crisis cells contain unsafe physical structures, such as tie-off points, and dangerous items that can be used for self-harm. Tags: mental_health,solitary,conditions,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Braggs v. Dunn: exercise 'cages' barely larger than segregation cells In Braggs v. Dunn, the court found that some Alabama prison facilities allow only one inmate at a time in a 'cage,' a subdivided section of the exercise yard that is fenced in and hardly bigger than the segregation cell itself, and that some yards, such as the one at Kilby, had fences totally enclosing the yard. Tags: solitary,conditions,facilities,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] DOJ: Parchman holds suicidal prisoners in non-suicide-resistant holding tanks In its findings report on the Mississippi State Penitentiary (Parchman), the DOJ found that incarcerated persons identified as suicidal, but who have not yet been technically admitted to Parchman's mental health unit, are held temporarily in one of three holding tanks on the first floor of the medical unit, and that these holding cells are also not suicide resistant because they are encased in metal bars. Tags: mental_health,conditions,medical,investigations Sources: justice.gov: mdoc parchman findings report 0 - [confirmed] DOJ: Parchman close custody is 23 hours/day lockdown In its findings report on the Mississippi State Penitentiary (Parchman), the DOJ found that people in close custody confinement are locked down alone in single cells, for 23 hours per day, with one hour out of cell for recreation and showers three times per week. Tags: solitary,conditions,investigations Sources: justice.gov: mdoc parchman findings report 0 - [reported] SCHR: Valdosta State Prison holding cages telephone-booth sized, no toilets, sinks, or beds The Southern Center for Human Rights' letter to GDC states that at Valdosta State Prison, people are confined for lengthy periods in small holding cages intended only for temporary confinement, about the size of a telephone booth, with no toilets, sinks, or beds, too small to accommodate substantial movement or allow people to lie down. Date: 2026-01-01 Tags: conditions,solitary,facilities Sources: SCHR Letter of Concern Re: Unconstitutional Conditions at VSP - [reported] SMU outdoor yard: twice-weekly standing in small cage A letter from the Southern Center for Human Rights to GDC states that inmates in the Special Management Unit at Georgia Diagnostic and Classification Prison are allowed to be outside in the yard twice a week where they must stand alone in a small cage. Tags: solitary,conditions Sources: Cameron Langford, "Inmate Advocates Push Georgia on Solitary-Confinement Harms," Courthouse News Service, 2017 - [confirmed] Nunez Monitor: Rikers intake toilet overflowing with feces, person sleeping on floor In a Special Report filed in Nunez v. City of New York, the Nunez Independent Monitor's February 2022 site visit found conditions at one Rikers intake to be particularly distressing, with a toilet overflowing with feces and an individual sleeping on the floor outside one of the intake pens. Date: 2022-03-16 Tags: conditions,facilities,legal Sources: Case 1:11-cv-05845-LTS-JCF Document 438 Filed 03/16/22 Page 1 of 78 - [confirmed] Nunez Monitor: Rikers intake conditions imploded, people held days or weeks In a Special Report filed in Nunez v. City of New York, the Nunez Independent Monitor found that the conditions of Rikers' intake units further imploded the previous summer, with some incarcerated individuals remaining in intake for days, if not weeks, in horrifying conditions. Date: 2022-03-16 Tags: conditions,facilities,legal Sources: Case 1:11-cv-05845-LTS-JCF Document 438 Filed 03/16/22 Page 1 of 78 - [reported] SCHR demands GDC stop housing people in VSP holding cages more than a few hours The SCHR letter demands GDC cease using small holding cages to house people at Valdosta State Prison for more than a few hours at a time. Date: 2026-01-01 Tags: conditions,solitary,policy,legal Sources: SCHR Letter of Concern Re: Unconstitutional Conditions at VSP - [reported] Atlanta Transitional Center Unit 1 temporary holding cells A PREA audit report on the Atlanta Transitional Center describes Unit 1's first floor as having 2 Temporary Holding Cells. Tags: conditions,facilities Sources: PREA Atlanta TC - Audit (Cycle 4) - [reported] AJC: SMU phased system and exercise pen twice a week The AJC reported that Southern Center for Human Rights filed a lawsuit alleging that the Special Management Unit (Tier III program) at Georgia Diagnostic and Classification Prison provided inmates 'an exercise pen twice a week' as part of a phased system, and that at its most restrictive, 'SMU does not allow inmates to leave their cells at all.' Tags: solitary,conditions,legal Sources: Lawsuit challenge extreme isolation at Georgia prison - [reported] SCHR: Valdosta prisoners held days or weeks in telephone-booth-sized cage without water, toilet, mattress The Southern Center for Human Rights states that people at Valdosta State Prison have been living for days or weeks in a small holding cage no larger than a telephone booth, with no access to running water, a toilet, or a mattress. Tags: conditions,facilities,solitary Sources: Horrific Conditions Create Humanitarian Crisis at Valdosta State Prison – Southern Center for Human Rights – Equality. Dignity. Justice., horrific conditions create humanitarian crisis at valdosta state prison [1] - [confirmed] DOJ SCI Cresson: restraint chair durations for prisoners with SMI In its DOJ findings letter on SCI Cresson, the Civil Rights Division found that numerous prisoners with serious mental illness were placed in restraints for an average of 10.5 hours at a time, and on at least two occasions prisoners were held in restraint chairs for closer to 20 hours; when restrained, prisoners typically were held in one fixed position in a windowless cement cell and were sometimes required to urinate while still in restraints. Tags: mental_health,conditions,solitary Sources: U.S. Department of Jnstice - [confirmed] DOJ SCI Cresson: ~23 hours/day isolation for prisoners with SMI In its DOJ findings letter on SCI Cresson, the Civil Rights Division found that Cresson routinely locks prisoners with serious mental illness in their cells for roughly 23 hours per day for months, even years, at a time, and that this prolonged isolation often involves unnecessary staff-on-prisoner uses of force. Tags: mental_health,solitary,conditions Sources: U.S. Department of Jnstice - [confirmed] Jensen v. Shinn: treatment in telephone booth-like cage in restraints In Jensen v. Shinn, the federal court for the District of Arizona found that when a maximum-custody prisoner requests a confidential, private mental-health session, he is placed in a 'telephone booth-like cage, still in restraints.' Tags: mental_health,solitary,conditions Sources: Case 2:12-cv-00601-ROS Document 4335 Filed 06/30/22 Page 1 of 200 - [confirmed] Jensen v. Shinn: recreation cages roughly cell-sized The Jensen v. Shinn order states those individual recreation cages are 'roughly the same size as a cell.' Tags: solitary,conditions Sources: Case 2:12-cv-00601-ROS Document 4335 Filed 06/30/22 Page 1 of 200 - [confirmed] Jensen v. Shinn: strip search and restraints before treatment cage The Jensen v. Shinn order found that maximum-custody prisoners 'must be strip searched before leaving their cells, placed in restraints, and placed in the cage, still in' restraints for mental-health treatment sessions. Tags: mental_health,solitary,conditions Sources: Case 2:12-cv-00601-ROS Document 4335 Filed 06/30/22 Page 1 of 200 - [confirmed] Jensen v. Shinn: treatment cage 'obviously inhospitable' The Jensen v. Shinn order states 'the treatment cage is "obviously inhospitable" and it makes it "difficult" for a' prisoner. Tags: mental_health,solitary,conditions Sources: Case 2:12-cv-00601-ROS Document 4335 Filed 06/30/22 Page 1 of 200 LEGAL FACTS (31) ---------------------------------------- - [reported] Stokes v. Johnson: one day in shower not Eighth Amendment violation An attorney blog states that a Georgia federal district court opinion in Stokes v. Johnson held that detention in a prison shower without a toilet, without ventilation, and without a mattress, for just one day, does not constitute cruel and unusual treatment under the Eighth Amendment. Date: 2024-05-01 Tags: solitary,legal,conditions Sources: Solitary Confinement in Georgia Prisons is "Draconian": Confinement in a Prison Shower is Immoral and Unconscionable - Atlanta Injury Lawyer Blog - May 1, 2024 - [confirmed] Williams v. Burton: continued force after resistance ceases can violate Eighth Amendment Williams v. Burton holds that once the necessity for the application of force ceases, any continued use of harmful force can be a violation of the Eighth and Fourteenth Amendments, and any abuse directed at the prisoner after he terminates his resistance to authority is an Eighth Amendment violation. Date: 1991-10-18 Tags: legal,conditions Sources: Williams v. Burton, U.S. Court of Appeals, 11th Circuit, 1991-10-18 (court record via CourtListener) - [reported] Stokes v. Johnson: court silent on 3-day shower detention The same blog post states the district court in Stokes v. Johnson did not reveal its thoughts about whether 3 days held in a shower would cross the line and violate the Eighth Amendment. Date: 2024-05-01 Tags: solitary,legal,conditions Sources: Solitary Confinement in Georgia Prisons is "Draconian": Confinement in a Prison Shower is Immoral and Unconscionable - Atlanta Injury Lawyer Blog - May 1, 2024 - [confirmed] Braggs v. Dunn definition of segregation: 22.5+ hours per day in cell In Braggs v. Dunn, the court described Alabama prison segregation as the correctional practice of keeping a prisoner in a cell for 22.5 hours or more a day, usually in a single-person cell, only letting the prisoner out for brief yard time and showers. Tags: solitary,legal,conditions Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Bibiano v. Garrett: joint motion to stay pending settlement (August 2025) In Bibiano v. Garrett, the parties filed a joint motion to stay proceedings pending settlement in August 2025, with responses due by 8/22/2025. Date: 2025-08-08 Tags: legal,conditions Sources: Bibiano v. Garrett, 2025-08-08 (court record via CourtListener) - [confirmed] Bibiano v. Garrett: plaintiff filed motion for settlement approval (October 2025) In Bibiano v. Garrett, the plaintiff filed a motion for settlement approval in October 2025. Date: 2025-10-01 Tags: legal,conditions Sources: Bibiano v. Garrett, 2025-08-08 (court record via CourtListener) - [confirmed] Rule 125-3-2-.10: hourly recorded inspection for close observation in Disciplinary Isolation Georgia Board of Corrections Rule 125-3-2-.10 requires that an inmate placed under close observation in Disciplinary Isolation (because classified as violent or likely to harm self/others) receive, at minimum, an hourly recorded inspection, with the Warden/Superintendent notifying the Commissioner of Corrections or an appropriate assistant. Tags: solitary,policy,legal Sources: Ga. Comp. R. & Regs. r. 125-3-2-.10, Procedures and Restrictions (Georgia Board of Corrections rule; passage checked against GPS's copy of the rule) - [confirmed] Sims v. Mashburn: magistrate found 29 hours in undershorts in concrete box justified relief In Sims v. Mashburn, the magistrate judge found that the discomfort and humiliation caused by being left for approximately 29 hours clothed only in undershorts in a concrete box justified relief, a finding adopted by the district judge. Date: 1994-07-12 Tags: solitary,conditions,legal Sources: Hardie Vertrain Sims, Jr. v. Mashburn, Officer, Coi, John B. Sanderson, Sgt., Gene Kelly, Officer, Coi Malone, Officer, Coi L. Burton, Warden, U.S. Court of Appeals, 11th Circuit, 1994-07-12 (court record via CourtListener) - [confirmed] Rule 125-3-2-.10: two-hour checks, three meals, and unlimited water in Disciplinary Isolation Georgia Board of Corrections Rule 125-3-2-.10 requires that an inmate confined to Disciplinary Isolation be checked on and observed at least every two hours (every hour when under close observation), with a signed record or checklist maintained, and be provided three meals (two hot) within a 24-hour period with no more than 14 hours between the evening meal and breakfast, and as much water as they wish to drink at all times. Tags: solitary,policy,legal,conditions Sources: Ga. Comp. R. & Regs. r. 125-3-2-.10, Procedures and Restrictions (Georgia Board of Corrections rule; passage checked against GPS's copy of the rule) - [confirmed] Gilmore v. GDC: en banc Eleventh Circuit strip-search ruling In Gilmore v. Georgia Department of Corrections, the en banc Eleventh Circuit held that, crediting Clarissa Gilmore's version of events, a jury could find that correctional officers at Smith State Prison violated her Fourth Amendment rights by subjecting her to a strip search without reasonable suspicion, and that the violation was one of obvious clarity such that the officers are not entitled to qualified immunity. Date: 2025-07-11 Tags: legal,investigations,facilities Sources: Clarissa Gilmore v. Georgia Department of Corrections, U.S. Court of Appeals, 11th Circuit, 2025-07-11 (court record via CourtListener) - [confirmed] Sims v. Mashburn: Eleventh Circuit doubted such harm meets Eighth Amendment threshold The Eleventh Circuit in Sims v. Mashburn entertained serious doubt about whether harm of this kind (discomfort and humiliation from 29 hours in undershorts in a concrete box) is objectively harmful enough to establish an Eighth Amendment violation. Date: 1994-07-12 Tags: solitary,conditions,legal Sources: Hardie Vertrain Sims, Jr. v. Mashburn, Officer, Coi, John B. Sanderson, Sgt., Gene Kelly, Officer, Coi Malone, Officer, Coi L. Burton, Warden, U.S. Court of Appeals, 11th Circuit, 1994-07-12 (court record via CourtListener) - [confirmed] Rule 125-3-2-.10: 30-day isolation cap without Division Director review; 60 days for single-incident series Georgia Board of Corrections Rule 125-3-2-.10 caps confinement to an isolation cell at thirty days without Division Director review and approval (sixty days for a series of infractions from a single incident), and requires at least 24 hours outside isolation if confinement exceeds 30 days even with approval. Tags: solitary,policy,legal Sources: Ga. Comp. R. & Regs. r. 125-3-2-.10, Procedures and Restrictions (Georgia Board of Corrections rule; passage checked against GPS's copy of the rule) - [confirmed] McClinton v. Warden: Eleventh Circuit affirms on failure-to-protect In McClinton v. Warden, Baldwin State Prison, the Eleventh Circuit affirmed summary judgment for Georgia Department of Corrections officials on an Eighth Amendment failure-to-protect claim arising from an inmate's stabbing death at Baldwin State Prison, holding that none of the defendants possessed the requisite subjective knowledge of the risk of harm to the inmate. Date: 2026-04-14 Tags: legal,violence,death Sources: Ricardo McClinton v. Warden, Baldwin State Prison, U.S. Court of Appeals, 11th Circuit, 2026-04-14 (court record via CourtListener) - [confirmed] Sims v. Mashburn: Eleventh Circuit reversed judgment against officer for cell stripping In Sims v. Mashburn, the Eleventh Circuit reversed a judgment against a prison officer who left an inmate's cell stripped of mattress, clothing and toilet water, holding that the evidence did not support a finding that the officer's failure to monitor the inmate after the stripping of his cell was conduct that can be characterized as malicious and sadistic, engaged in for the purpose of causing harm. Date: 1994-07-12 Tags: solitary,conditions,legal Sources: Hardie Vertrain Sims, Jr. v. Mashburn, Officer, Coi, John B. Sanderson, Sgt., Gene Kelly, Officer, Coi Malone, Officer, Coi L. Burton, Warden, U.S. Court of Appeals, 11th Circuit, 1994-07-12 (court record via CourtListener) - [confirmed] Chandler v. Crosby: Eighth Amendment objective component requires 'extreme' condition Chandler v. Crosby holds that under the Eighth Amendment's objective component, a prisoner must prove that the condition he complains of is sufficiently serious to violate the Eighth Amendment, and the challenged condition must be 'extreme.' Date: 2004-08-06 Tags: legal,conditions Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Chandler v. Crosby: Eighth Amendment requires assessing severity and duration of heat/ventilation exposure Chandler v. Crosby describes the cells at issue as each a completely enclosed cell and finds the Eighth Amendment is concerned with both the severity and the duration of a prisoner's exposure to unpleasant conditions in evaluating heat and ventilation conditions, requiring more than a scientific and statistical inquiry and an assessment of whether society considers the risk so grave that it violates contemporary standards of decency. Date: 2004-08-06 Tags: legal,conditions,facilities Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Taylor v. Riojas: six days in feces-covered cell unconstitutional In Taylor v. Riojas, the Supreme Court held that no reasonable correctional officer could have concluded it was constitutionally permissible to house inmate Trent Taylor in cells described as covered in massive amounts of feces and with a clogged drain causing raw sewage to spill across the floor, for six days. Date: 2020-11-02 Tags: conditions,legal Sources: Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener) - [confirmed] Taylor v. Riojas cites Hope v. Pelzer on obvious cruelty providing notice Taylor v. Riojas quotes Hope v. Pelzer for the proposition that a general constitutional rule already identified in decisional law may apply with obvious clarity to the specific conduct in question, and that the obvious cruelty inherent in wantonly degrading and dangerous situations provides officers notice their conduct violates the Eighth Amendment. Date: 2020-11-02 Tags: legal Sources: Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener) - [confirmed] Hope v. Pelzer: hitching post beyond order restoration violates Eighth Amendment In Hope v. Pelzer, the Supreme Court held that the policy and practice of cuffing an inmate to a hitching post or similar stationary object for a period of time that surpasses that necessary to quell a threat or restore order is a violation of the Eighth Amendment. Date: 2002-06-27 Tags: legal,conditions Sources: Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener) - [confirmed] Hope v. Pelzer: general constitutional rule may apply with obvious clarity Hope v. Pelzer holds that a general constitutional rule already identified in the decisional law may apply with obvious clarity to the specific conduct in question, even though the very action in question has not previously been held unlawful, quoting United States v. Lanier. Date: 2002-06-27 Tags: legal Sources: Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener) - [confirmed] Hope v. Pelzer cites Farmer v. Brennan on inferring deliberate indifference from obvious risk Hope v. Pelzer cites Farmer v. Brennan for the proposition that the existence of deliberate indifference may be inferred from the fact that the risk of harm is obvious, in the context of determining whether prison officials acted with deliberate indifference to inmates' health or safety. Date: 2002-06-27 Tags: legal Sources: Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener) - [confirmed] Hope v. Pelzer quotes Rhodes v. Chapman on pain without penological justification Hope v. Pelzer quotes Rhodes v. Chapman for the standard that among unnecessary and wanton inflictions of pain are those that are totally without penological justification. Date: 2002-06-27 Tags: legal Sources: Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener) - [confirmed] Coleman v. Newsom: plaintiffs' objection to TTMs In a Coleman v. Newsom stipulation, plaintiffs maintained their objection that the use of Therapeutic Treatment Modules (TTMs) in any treatment setting, including defendants' Psychiatric Inpatient Programs, is violative of the Eighth Amendment. Tags: mental_health,legal,solitary Sources: 1 ROB BONTA, State Bar No. 202668 HANSON BRIDGETT LLP - [confirmed] Coleman v. Newsom: defendants' position on TTMs In a Coleman v. Newsom stipulation, defendants contended that the use of Therapeutic Treatment Modules (TTMs) to deliver mental health care to Max custody patients does not violate the Eighth Amendment, and that nothing in the agreement should be construed as an admission of such. Tags: mental_health,legal,solitary Sources: 1 ROB BONTA, State Bar No. 202668 HANSON BRIDGETT LLP - [confirmed] Rhodes v. Chapman: Eighth Amendment prohibits unnecessary and wanton infliction of pain Rhodes v. Chapman holds that the Eighth Amendment prohibits punishments which, although not physically barbarous, involve the unnecessary and wanton infliction of pain, or are grossly disproportionate to the severity of the crime, and that among unnecessary and wanton inflictions of pain are those that are totally without penological justification. Date: 1981-06-15 Tags: legal Sources: Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener) - [confirmed] Brooks v. Warden: Deputy Warden Powell denied qualified immunity for unsanitary confinement In Brooks v. Warden, the Eleventh Circuit held that Deputy Warden Powell was not entitled to qualified immunity on the claim that Brooks had been confined in conditions lacking in basic sanitation, because he was put on fair notice both by caselaw and the knowledge that forcing a prisoner to soil himself over a two-day period while chained in a hospital bed creates an obvious health risk and is an affront to human dignity. Date: 2015-01-01 Tags: legal,conditions,solitary Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Wilson v. Seiter: conditions claims require inquiry into official's state of mind Wilson v. Seiter presented the question whether a prisoner claiming that conditions of confinement constitute cruel and unusual punishment must show a culpable state of mind on the part of prison officials, and held that such claims mandate inquiry into a prison official's state of mind. Date: 1991-06-17 Tags: legal Sources: Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener) - [confirmed] Wilson v. Seiter: required state of mind in prison-conditions cases is deliberate indifference Wilson v. Seiter held that Eighth Amendment claims based on official conduct that does not purport to be the penalty formally imposed for a crime require inquiry into state of mind, and that in cases challenging prison conditions the required state of mind is deliberate indifference. Date: 1991-06-17 Tags: legal Sources: Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener) - [confirmed] Farmer v. Brennan: deliberate indifference requires subjective awareness of risk Farmer v. Brennan holds that a prison official's deliberate indifference to a substantial risk of serious harm to an inmate violates the Eighth Amendment, and defines deliberate indifference by requiring a showing that the official was subjectively aware of the risk. Date: 1994-06-06 Tags: legal Sources: Farmer v. Brennan, Supreme Court of the United States, 1994-06-06 (court record via CourtListener) - [confirmed] Farmer v. Brennan: two requirements for Eighth Amendment violation Farmer v. Brennan holds that a prison official violates the Eighth Amendment only when two requirements are met: the deprivation alleged must be objectively sufficiently serious, and the official must have a sufficiently culpable state of mind, which in prison-conditions cases is deliberate indifference to inmate health or safety. Date: 1994-06-06 Tags: legal Sources: Farmer v. Brennan, Supreme Court of the United States, 1994-06-06 (court record via CourtListener) - [confirmed] Hudson v. McMillian: core inquiry is whether force applied maliciously and sadistically Hudson v. McMillian holds that whenever prison officials stand accused of using excessive physical force in violation of the Cruel and Unusual Punishments Clause, the core judicial inquiry is whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm. Date: 1992-02-25 Tags: legal,violence Sources: Hudson v. McMillian, Supreme Court of the United States, 1992-02-25 (court record via CourtListener) POLICYS (15) ---------------------------------------- - [confirmed] SOP 209.07: 96-hour Tier I classification hearing requirement GDC's Tier I Segregation policy (covering disciplinary, protective custody and transient housing) requires the Warden/Superintendent to ensure the Classification Committee holds a formal hearing within ninety-six (96) hours after an offender is involuntarily placed in the Tier I Program. Tags: solitary,policy,legal Sources: Georgia Department of Corrections SOP 209.07, Segregation-Tier I_ Disciplinary, Protective Custody and Transient Housing (GPS's copy) - [confirmed] SOP 209.07: medical round schedule in Tier I segregation GDC's Tier I Segregation policy requires Health Care officials to conduct an initial medical round within the first 24 hours after placement in the unit and then at a minimum of three times a week (excluding weekends and holidays) at state facilities, and at least once every 72 hours at county correctional facilities. Tags: solitary,policy,medical Sources: Georgia Department of Corrections SOP 209.07, Segregation-Tier I_ Disciplinary, Protective Custody and Transient Housing (GPS's copy) - [confirmed] SOP 209.06: 30-minute documented checks in administrative segregation GDC's Administrative Segregation policy requires individual records for each offender to be completed daily with 30-minute documented checks, documented when they occur rather than at the end of the shift; false entries are prohibited, no rounds may be skipped or documented in advance, and more frequent rounds may be required for offenders who are violent, mentally disordered, or potentially suicidal or self-injurious. Tags: solitary,policy,mental_health Sources: SOP 209.06: Administrative Segregation - [confirmed] SOP 507.04.35: definition of a Stripped Cell GDC's use-of-force examination policy defines a Stripped Cell as any cell from which staff have removed any one of: a serviceable bed, fire-retardant mattress, hot and cold running water, a working toilet, or proper bedding (one pillow, one pillowcase, one blanket (seasonal), two sheets). Tags: solitary,policy,conditions Sources: Georgia Department of Corrections SOP 507.04.35, Examination Following Use of Force (passage checked against GPS's copy) - [reported] Atlanta Transitional Center holding cell limit: 8 hours A PREA audit report on the Atlanta Transitional Center (a GDC facility) states the Superintendent stated a resident may stay in the holding cell for no more than eight (8) hours. Tags: conditions,facilities,policy Sources: PREA Atlanta - Audit (Cycle 2) - [confirmed] SOP 209.04: water offered at least every two hours in Safety Restraint Chair GDC's Safety Restraint Chair policy requires an offender be offered water whenever appropriate and at least every two hours to maintain hydration, documented in the official logbook. Tags: policy,conditions,operations Sources: Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy) - [confirmed] SOP 209.04: fifteen-minute checks documented on Segregation/Isolation Checklist GDC's Safety Restraint Chair policy requires fifteen-minute checks to be completed and documented on the Segregation/Isolation Checklist. Tags: policy,conditions,operations Sources: Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy) - [confirmed] SOP 209.04: hourly review, two-hour chair limit without Warden authorization, two-hour health reassessment GDC's Safety Restraint Chair policy requires the Chief of Security or Shift O.I.C. to review use of the Safety Restraint Chair once every hour, ensure no offender is kept in the chair more than two hours without Warden/Superintendent authorization, and requires a qualified health care professional to reassess the offender's mental and medical health status every two hours. Tags: policy,conditions,medical,operations Sources: Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy) - [confirmed] SOP 209.04: bathroom break offered every two hours after initial two-hour span GDC's Safety Restraint Chair policy requires a bathroom break to be offered every two hours after the initial two-hour time span. Tags: policy,conditions,operations Sources: Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy) - [confirmed] SOP 209.04: bathroom opportunity at least once every two hours, documented in logbook GDC's Safety Restraint Chair policy requires the offender be given the opportunity to use the bathroom at least once every two hours, documented in the official logbook. Tags: policy,conditions,operations Sources: Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy) - [confirmed] SOP 209.05: stripped cell observation at least every 15 minutes, documented and signed GDC's stripped cell policy requires any inmate/probationer assigned to a stripped cell to be observed by security staff at least every 15 minutes, with observation documented by date, time and behavior, signed by the observing staff member. Tags: policy,conditions,operations Sources: SOP 209.05, Stripped Cells and Temporary Confiscation of Personal Property - [confirmed] SOP 209.05: stripped cell is a cooling-off period ordinarily no more than eight hours GDC's stripped cell policy states confinement to a stripped cell is intended only as a "cooling off" period and shall ordinarily be for no more than eight hours. Tags: policy,conditions,operations Sources: SOP 209.05, Stripped Cells and Temporary Confiscation of Personal Property - [confirmed] SOP 209.05: continued stripped-cell confinement requires medical and Warden authorization; 72-hour report GDC's stripped cell policy requires that continued confinement beyond the initial eight-hour period have written authorization by the senior medical employee after telephonic approval by a physician or physician's assistant, renewed daily by a physician or senior medical staff, plus daily written authorization of the Warden or Superintendent, and that if confinement continues for 72 hours the senior medical employee must provide a written report on the inmate's mental and physical stability. Tags: policy,conditions,medical,operations Sources: SOP 209.05, Stripped Cells and Temporary Confiscation of Personal Property - [confirmed] SOP 508.28: Observation Cells serve safety and temporary holding functions GDC's policy on managing potentially suicidal, self-injurious and assaultive offenders states the primary functions of Observation Cells are safety and temporary holding. Tags: policy,mental_health,conditions Sources: Georgia Department of Corrections SOP 508.28, Managing Potentially Suicidal, Self-Injurious, and Assaultive Behavior (passage checked against GPS's copy) - [confirmed] SOP 508.28: fifteen-minute watch minimum and 24-hour limit before Warden notification GDC's policy on managing potentially suicidal, self-injurious and assaultive offenders requires offenders placed in Observation Cells to be on a fifteen-minute watch at minimum, and states placement is not to exceed twenty-four hours without a notification to the Warden, Regional Director, and Statewide Mental Health Director justifying placement beyond that period. Tags: policy,mental_health,conditions Sources: Georgia Department of Corrections SOP 508.28, Managing Potentially Suicidal, Self-Injurious, and Assaultive Behavior (passage checked against GPS's copy) STATISTICS (5) ---------------------------------------- - [reported] GDCP Special Management Unit bed count Courthouse News reports that the Special Management Unit at the Georgia Diagnostic and Classification Prison has 192 beds, and that an expert, Haney, toured the facility and interviewed inmates in October 2017. Value: 192.0 beds Date: 2017-10-01 Tags: solitary,facilities,conditions Sources: Cameron Langford, "Inmate Advocates Push Georgia on Solitary-Confinement Harms," Courthouse News Service, 2017 - [confirmed] DOJ: Parchman restrictive housing average 515 days In its findings report on the Mississippi State Penitentiary (Parchman), the DOJ found that people in close custody confinement at Parchman are held in restrictive housing for an average of 515 days, and many are held there for several years, with about a quarter of the incarcerated persons in close confinement held in restrictive housing for over two years straight and counting, and over half held in restrictive housing for more than a year. Value: 515.0 days Tags: solitary,conditions,investigations Sources: justice.gov: mdoc parchman findings report 0 - [reported] SCHR: 13 of 15 interviewees saw people held in VSP cages from two days to three weeks The Southern Center for Human Rights letter states that the practice of holding people in cages at Valdosta State Prison is so prevalent that 13 of the 15 individuals interviewed reported seeing other incarcerated people in a holding cage for anywhere from two to three days to two to three weeks. Value: 13.0 of 15 interviewees Date: 2026-01-01 Tags: conditions,solitary,facilities Sources: SCHR Letter of Concern Re: Unconstitutional Conditions at VSP - [confirmed] Coleman v. Brown: MHCB transfer wait times, September 2016 In a Coleman v. Brown order on mental health crisis bed (MHCB) transfers, the court found that in September 2016, a total of 448 class members were transferred to MHCBs, with an average wait time for transfer of 86.45 hours, and only nine class members transferred in less than 24 hours. Value: 448.0 class members (vs. 86.45 average wait time (hours)) Date: 2016-09-01 Tags: mental_health,transfers,legal Sources: govinfo.gov: USCOURTS caed 2 90 cv 00520 831 - [reported] Lawsuit: at least 12 suicides at Georgia State Prison in two years before filing The AP reported that a lawsuit against GDC officials states at least 12 men died by suicide at Georgia State Prison in the two years before the lawsuit was filed, including some who were held in solitary confinement at the time. Value: 12.0 suicides Tags: death,mental_health,solitary,legal Sources: Solitary confinement in Georgia prison overly harsh, lawsuit alleges Please ensure Javascript is enabled for purposes of website accessibility KEY ENTITIES (65) ---------------------------------------- - Alabama Department of Corrections [organization]: Alabama state corrections agency spending approximately $19.3 million on prison education (~$742/inmate/year) while under federal oversight for unconstitutional conditions - Atlanta Transitional Center [facility]: GDC transitional center in Atlanta, Georgia. Current facility for Aaron Keith Penn (listed as INACTIVE). - Baldwin State Prison [facility]: Georgia state prison where 26 grams of methamphetamine were found on a visitor in November 2025. - Bibiano v. Garrett [case]: Case dismissed with prejudice by Judge Dudley H. Bowen on March 23, 2026. - Braggs v. Dunn [case]: M.D. Ala. Eighth Amendment class action on mental-health care in Alabama prisons; 2017 liability opinion found Commissioner and Associate Commissioner of Health Services violated the Eighth Amendment. (aka: Case 2:14-cv-00601-MHT-TFM) - Brooks v. Warden [case]: Eleventh Circuit (2015) decision affirming dismissal of a riot failure-to-protect claim but reviving a basic-sanitation claim and denying qualified immunity to the deputy warden. (aka: Fred Dalton Brooks v. Warden) - Carl Humphrey [person]: Warden named as a defendant in Brooks v. Warden. (aka: Warden Carl Humphrey) - Chandler v. Crosby [case]: Eleventh Circuit decision holding that the Eighth Amendment applies to inadequate cooling and ventilation but that mere discomfort does not offend it; controlling heat precedent for Georgia federal courts. (aka: 379 F.3d 1278 (11th Cir. 2004)) - Clarissa Gilmore [person]: Plaintiff in Gilmore v. Georgia Department of Corrections, strip-search case decided en banc by the Eleventh Circuit in 2025. - Coleman v. Brown [case]: Federal class action filed 1990 challenging failure to diagnose and treat mental illness in California prisons; ongoing for 35 years; led to 2025 receivership (aka: Coleman v. Wilson, Coleman v. Wilson, 912 F. Supp. 1282 (E.D. Cal. 1995)) - Coleman v. Newsom [case]: California class action stipulation addressing Therapeutic Treatment Modules (TTMs) and Eighth Amendment objections. - DOJ Civil Rights Division [organization]: Federal agency that conducted the investigation of Georgia prisons resulting in the October 2024 findings report (aka: U.S. Department of Justice, DOJ) - Eleventh Circuit [organization]: Federal appellate court with jurisdiction over Georgia, Florida and Alabama; author of Chandler v. Crosby. (aka: U.S. Court of Appeals for the Eleventh Circuit) - Farmer v. Brennan [case]: U.S. Supreme Court case establishing the deliberate indifference two-part test (objective + subjective components) for Eighth Amendment prison conditions claims. The bedrock case for all prisoner rights litigation. (aka: 511 U.S. 825 (1994)) - Fred Dalton Brooks [person]: Incarcerated person at GDCP's Special Management Unit who brought Eighth Amendment claims in Brooks v. Warden. (aka: Brooks) - Georgia Board of Corrections [organization]: Governing board that issues rules for Georgia prison operations, including Rule 125-4-2-.08 (Library) and Rule 125-2-4-.17 - Georgia Department of Corrections [organization]: State agency responsible for operating Georgia's prison system. Subject of federal DOJ investigation in 2022-2023 for constitutional violations including food-related deaths. (aka: GDC) - Georgia Department of Corrections SOP 209.07 [legislation]: GDC standard operating procedure governing Tier I segregation (disciplinary, protective custody, transient housing). (aka: SOP 209.07) - Georgia Department of Corrections SOP 507.04.35 [legislation]: GDC standard operating procedure on examination following use of force, defining a Stripped Cell. (aka: SOP 507.04.35) - Georgia Diagnostic and Classification Prison [facility]: Georgia state prison from which David 'Toro' Zavala operated drug trafficking while serving time for armed robbery. - Georgia State Prison [facility]: Georgia state prison where Chad Ashley Allen, serving a life sentence for murder, operated drug trafficking enterprise with Ghost Face Gangsters. - Gilmore v. Georgia Department of Corrections [case]: En banc Eleventh Circuit decision (2025) discussing Taylor v. Riojas and the obvious-clarity standard for Eighth Amendment claims. (aka: Clarissa Gilmore v. Georgia Department of Corrections) - Hardie Vertrain Sims, Jr. [person]: Inmate plaintiff in Sims v. Mashburn. - Hays State Prison [facility]: Georgia state prison visited by DOJ during 2022-2023 investigation (aka: Hays) - Hope v. Pelzer [case]: U.S. Supreme Court case, 536 U.S. 730 (2002), arising from Alabama. Held that handcuffing a prisoner to a hitching post for seven hours in the sun constituted obvious cruel and unusual punishment. Directly analogous to Georgia heat exposure cases. - Hudson v. McMillian [case]: Supreme Court case distinguishing excessive force claims from conditions-of-confinement claims. - James McMillan [person]: SMU Unit Manager named as a defendant in Brooks v. Warden. (aka: SMU Unit Manager James McMillan) - Jensen v. Shinn [case]: Arizona federal case (D. Ariz.) addressing treatment cages and restraints for maximum-custody prisoners. - John B. Sanderson [person]: Prison officer whose failure to monitor an inmate after cell stripping was at issue in Sims v. Mashburn. (aka: Sgt. John B. Sanderson) - Juan Carlos Ramirez [person]: 27-year-old man who died from alleged extreme heat exposure at Telfair State Prison, per a 2024 lawsuit. - Juan Carlos Ramirez Bibiano [person]: 27-year-old prisoner who died on July 20, 2023 at Telfair State Prison after being left in an outdoor recreation cage for five hours in 105°F heat index. Internal body temperature reached 107°F. GDC reported death as 'natural causes.' Subject of Bibiano v. McFarlane lawsuit. (aka: Juan Carlos Ramirez) - June Bishop [person]: Deputy Warden named as a defendant in Brooks v. Warden. (aka: Deputy Warden June Bishop) - Kilby Correctional Facility [facility]: Alabama prison whose exercise yard was described in Braggs v. Dunn as having fences totally enclosing the yard. (aka: Kilby) - Larry Hope [person]: Inmate handcuffed to a hitching post for approximately seven hours in Hope v. Pelzer. - McClinton v. Warden, Baldwin State Prison [case]: Eleventh Circuit appeal affirming summary judgment for defendants in suit over Jamari McClinton's death. (aka: Ricardo McClinton v. Warden) - Mississippi State Penitentiary (Parchman) [facility]: Mississippi state prison that received the first MAS deployment in 2010 using Tecore iNAC technology. (aka: Parchman) - Norma Bibiano [person]: Plaintiff in Bibiano v. Garrett. - Nunez Independent Monitor [organization]: Court-appointed monitor overseeing reforms at Rikers under Nunez v. City of New York. (aka: Monitoring Team) - Nunez v. City of New York [case]: Federal case (S.D.N.Y.) under which the Nunez Independent Monitor filed a March 2022 Special Report on Rikers intake conditions. - Ramirez [person]: 27-year-old man with a mental health provider meeting whose death from extreme heat exposure in an outdoor rec cell is the subject of a 2024 lawsuit. - Rhodes v. Chapman [case]: Supreme Court case holding that double-celling is not per se unconstitutional under the Eighth Amendment (aka: 452 U.S. 337 (1981)) - Ricardo McClinton [person]: Inmate whose stabbing death at Baldwin State Prison was the subject of McClinton v. Warden. - Rikers Island [facility]: New York City jail complex subject to Nunez v. City of New York monitoring; intake conditions described in a 2022 Special Report. (aka: Rikers) - Rogers State Prison [facility]: Georgia state prison where two violent incidents occurred during a 2-day DOJ visit in March 2023, including gang fight with multiple knives, 2 airlifts, 5 ambulance transports; warden had been arrested for gang participation less than 2 months prior - Rule 125-3-2-.10 [legislation]: Georgia Board of Corrections rule governing Disciplinary Isolation procedures and restrictions. (aka: Ga. Comp. R. & Regs. r. 125-3-2-.10) - SCI Cresson [facility]: Pennsylvania state prison subject of a 2013 DOJ findings letter on restraint and isolation of prisoners with serious mental illness. - Sims v. Mashburn [case]: Eleventh Circuit case (1994) in which the court reversed judgment against an officer for stripping an inmate's cell and doubted whether 29 hours in undershorts in a concrete box met the Eighth Amendment threshold. - Smith State Prison [facility]: Georgia state prison targeted by drone smuggling networks; subject of Operation Night Drop indictments. - SOP 209.04 [organization]: GDC standard operating procedure governing use of force and restraint, including the Safety Restraint Chair. (aka: Use of Force and Restraint for Offender Control) - SOP 209.05 [legislation]: GDC policy effective 04/30/2015, Authority Bryson/Jacobs, 5 pages, PowerDMS id 105939. Governs stripped cells: emergency use only, never punishment, written Warden authorization, 8-hour initial maximum, daily medical authorization, and MH/MR evaluation requirements. (aka: Stripped Cells and Temporary Confiscation of Personal Property, IIB08-0005) - SOP 209.06 [organization]: GDC policy governing involuntary Administrative Segregation assignment appeals. - SOP 508.28 [organization]: GDC standard operating procedure governing observation cells and management of suicidal, self-injurious, and assaultive offenders. (aka: Managing Potentially Suicidal, Self-Injurious, and Assaultive Behavior) - Southern Center for Human Rights [organization]: Legal advocacy organization that investigated food conditions at Gordon County Jail and sent a formal letter to Sheriff Mitch Ralston in October 2014. (aka: SCHR) - Special Management Unit [facility]: Georgia's primary long-term solitary confinement unit, located at Georgia Diagnostic and Classification Prison in Jackson. Subject of Gumm v. Jacobs litigation and described by experts as 'one of the harshest and most draconian' in the nation. (aka: SMU) - Stokes v. Johnson [case]: Georgia federal district court case holding one day in a shower without toilet, ventilation, or mattress is not an Eighth Amendment violation. - Supreme Court of the United States [organization]: Highest federal court, which decided Hutto v. Finney and Miller v. French. (aka: Supreme Court) - Taylor v. Riojas [case]: Supreme Court case establishing that some conduct is so obviously unconstitutional that no prior case is needed to overcome qualified immunity; involved prisoner held in feces-covered cells for 6 days (aka: 141 S. Ct. 52 (2020)) - Telfair State Prison [facility]: Georgia state prison involved in Operation Ghost Busted (Desiree Briley) and Operation Night Drop drone smuggling network. - Trent Taylor [person]: Inmate whose conditions of confinement were at issue in Taylor v. Riojas. - U.S. Department of Justice [organization]: Federal agency that published October 2024 findings report on unconstitutional conditions in Georgia prisons. (aka: DOJ) - United States v. Lanier [case]: Supreme Court decision (520 U.S. 259 (1997)) holding the 'clearly established' fair-warning requirement applies in criminal civil-rights prosecutions. - Ware State Prison [facility]: Georgia state prison leading all GDC facilities in cell phone seizures by end of 2016, with 1,392 phones confiscated. - William Powell [person]: Plaintiff in a federal complaint alleging at least 60 knife attacks at Macon State Prison. - Williams v. Burton [case]: Eleventh Circuit case (1991) holding that 28.5 hours in four-point restraints with mouth taped did not violate the Eighth Amendment absent actual injury, while affirming that continued force after resistance ceases can violate the Eighth and Fourteenth Amendments. - Wilson v. Seiter [case]: 1991 Supreme Court case extending deliberate indifference standard to conditions of confinement and establishing Section 1983 liability for administrators SOURCES (39) ---------------------------------------- - 1 ROB BONTA, State Bar No. 202668 HANSON BRIDGETT LLP, govinfo.gov [legal_document, primary] URL: https://www.govinfo.gov/content/pkg/USCOURTS-caed-2_90-cv-00520/pdf/USCOURTS-caed-2_90-cv-00520-1157.pdf - A Georgia inmate died from heat exposure. Left with questions, his family is suing the state | Georgia Public Broadcasting, Georgia Public Broadcasting (2024-07-26) [journalism, secondary] URL: https://web.archive.org/web/20260214161247id_/https://www.gpb.org/news/2024/07/26/georgia-inmate-died-heat-exposure-left-questions-his-family-suing-the-state - Bibiano v. Garrett, 2025-08-08 (court record via CourtListener), CourtListener (2025-08-08) [legal_document, primary] URL: https://www.courtlistener.com/docket/69640578/ - Cameron Langford, "Inmate Advocates Push Georgia on Solitary-Confinement Harms," Courthouse News Service, 2017, Courthouse News Service by Cameron Langford (2017-01-01) [journalism, secondary] URL: https://www.courthousenews.com/inmate-advocates-push-georgia-on-solitary-confinement-harms/ - Case 1:11-cv-05845-LTS-JCF Document 438 Filed 03/16/22 Page 1 of 78, Nunez Independent Monitor (2022-03-16) [legal_document, primary] URL: https://tillidgroup.com/wp-content/uploads/2022/03/Special-Report-03-16-22-As-Filed.pdf - Case 2:12-cv-00601-ROS Document 4335 Filed 06/30/22 Page 1 of 200, U.S. District Court for the District of Arizona (2022-06-30) [legal_document, primary] URL: https://clearinghouse-umich-production.s3.amazonaws.com/media/doc/131544.pdf - Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302, Southern Poverty Law Center (2017-06-27) [legal_document, primary] URL: https://www.splcenter.org/wp-content/uploads/files/documents/the_opinion.pdf - Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004), U.S. Court of Appeals for the Eleventh Circuit (2004-08-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/76715/jim-e-chandler-v-james-crosby/ - Clarissa Gilmore v. Georgia Department of Corrections, U.S. Court of Appeals, 11th Circuit, 2025-07-11 (court record via CourtListener), CourtListener (2025-07-11) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10631717/clarissa-gilmore-v-georgia-department-of-corrections/ - DOJ Findings Report: Investigation of Georgia Prisons (October 2024), U.S. Department of Justice (2024-10-01) [official_report, primary] URL: https://www.justice.gov/d9/2024-09/findings_report_-_investigation_of_georgia_prisons.pdf - Farmer v. Brennan, Supreme Court of the United States, 1994-06-06 (court record via CourtListener), CourtListener (1994-06-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/1087956/farmer-v-brennan/ - Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener), CourtListener (2015-09-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2844883/fred-dalton-brooks-v-warden/ - Ga. Comp. R. & Regs. r. 125-3-2-.10, Procedures and Restrictions (Georgia Board of Corrections rule; passage checked against GPS's copy of the rule), Georgia Secretary of State [legislation, primary] URL: https://rules.sos.ga.gov/gac/125-3-2-.10 - Georgia Department of Corrections SOP 209.04, Use of Force and Restraint for Offender Control (passage checked against GPS's copy), Georgia Department of Corrections [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105937 - Georgia Department of Corrections SOP 209.07, Segregation-Tier I_ Disciplinary, Protective Custody and Transient Housing (GPS's copy), Georgia Prisoners' Speak (2026-01-01) [official_report, primary] URL: https://gps.press/sop-data/209.07/ - Georgia Department of Corrections SOP 507.04.35, Examination Following Use of Force (passage checked against GPS's copy), Georgia Department of Corrections [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/106371 - Georgia Department of Corrections SOP 508.28, Managing Potentially Suicidal, Self-Injurious, and Assaultive Behavior (passage checked against GPS's copy), Georgia Department of Corrections [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/106290 - govinfo.gov: USCOURTS caed 2 90 cv 00520 831, govinfo.gov [legal_document, primary] URL: https://www.govinfo.gov/content/pkg/USCOURTS-caed-2_90-cv-00520/pdf/USCOURTS-caed-2_90-cv-00520-831.pdf - Hardie Vertrain Sims, Jr. v. Mashburn, Officer, Coi, John B. Sanderson, Sgt., Gene Kelly, Officer, Coi Malone, Officer, Coi L. Burton, Warden, U.S. Court of Appeals, 11th Circuit, 1994-07-12 (court record via CourtListener), CourtListener (1994-07-12) [legal_document, primary] URL: https://www.courtlistener.com/opinion/670830/hardie-vertrain-sims-jr-v-mashburn-officer-coi-john-b-sanderson/ - Hope v. Pelzer, Supreme Court of the United States, 2002-06-27 (court record via CourtListener), CourtListener (2002-06-27) [legal_document, primary] URL: https://www.courtlistener.com/opinion/121169/hope-v-pelzer/ - Horrific Conditions Create Humanitarian Crisis at Valdosta State Prison – Southern Center for Human Rights – Equality. Dignity. Justice., Southern Center for Human Rights (2026-10-01) [press_release, primary] URL: https://web.archive.org/web/20261002072427id_/https://www.schr.org/horrific-conditions-create-humanitarian-crisis-at-valdosta-state-prison/ - Horrific Conditions Create Humanitarian Crisis at Valdosta State Prison – Southern Center for Human Rights – Equality. Dignity. Justice., horrific conditions create humanitarian crisis at valdosta state prison [1], Southern Center for Human Rights (2026-01-01) [official_report, primary] URL: https://web.archive.org/web/2026/https://www.schr.org/horrific-conditions-create-humanitarian-crisis-at-valdosta-state-prison/ - Hudson v. McMillian, Supreme Court of the United States, 1992-02-25 (court record via CourtListener), CourtListener (1992-02-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/112693/hudson-v-mcmillian/ - justice.gov: mdoc parchman findings report 0, U.S. Department of Justice (2022-04-20) [official_report, primary] URL: https://www.justice.gov/d9/press-releases/attachments/2022/04/20/mdoc_parchman_findings_report_0.pdf - Lawsuit challenge extreme isolation at Georgia prison, The Atlanta Journal-Constitution [journalism, secondary] URL: https://web.archive.org/web/20251009081418id_/https://www.ajc.com/news/local/lawsuit-extreme-isolation-georgia-prison-amounts-torture/8aD46kZmiJdWxNqEPzA4DM/ - Lawsuit: 27-year-old man died from extreme heat exposure at state prison, Atlanta News First, July 25, 2024, Atlanta News First (2024-07-25) [journalism, secondary] URL: https://www.atlantanewsfirst.com/2024/07/25/lawsuit-27-year-old-man-died-extreme-heat-exposure-state-prison/ - PREA Atlanta - Audit (Cycle 2), Georgia Department of Corrections [official_report, primary] URL: https://gdc.georgia.gov/document/prea-audit-location-report/prea-atlanta-audit-cycle-2/download - PREA Atlanta TC - Audit (Cycle 4), Georgia Department of Corrections [official_report, primary] URL: https://gdc.georgia.gov/document/prea-audit-location-report/prea-atlanta-tc-audit-cycle-4/download - Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener), CourtListener (1981-06-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/110518/rhodes-v-chapman/ - Ricardo McClinton v. Warden, Baldwin State Prison, U.S. Court of Appeals, 11th Circuit, 2026-04-14 (court record via CourtListener), CourtListener (2026-04-14) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10842610/ricardo-mcclinton-v-warden-baldwin-state-prison/ - SCHR Letter of Concern Re: Unconstitutional Conditions at VSP, Southern Center for Human Rights by Alison Ganem; Atteeyah Hollie (2026-10-01) [legal_document, primary] URL: https://www.schr.org/wp-content/uploads/20262026.10.01-Letter-of-Concern-Re-Unconstitutional-Conditions-at-VSP.pdf - Solitary confinement in Georgia prison overly harsh, lawsuit alleges Please ensure Javascript is enabled for purposes of website accessibility, NewsChannel 9 [journalism, secondary] URL: https://newschannel9.com/news/local/solitary-confinement-in-georgia-prison-overly-harsh-lawsuit-alleges - Solitary Confinement in Georgia Prisons is "Draconian": Confinement in a Prison Shower is Immoral and Unconscionable - Atlanta Injury Lawyer Blog - May 1, 2024, Atlanta Injury Lawyer Blog (2024-05-01) [journalism, secondary] URL: https://www.atlantainjurylawyerblog.com/solitary-confinement-in-georgia-prisons-is-draconian-confinement-in-a-prison-shower-is-immoral-and-unconscionable/ - SOP 209.05, Stripped Cells and Temporary Confiscation of Personal Property, Georgia Department of Corrections by Bryson/Jacobs (2015-04-30) [legal_document, primary] URL: https://public.powerdms.com/GADOC/documents/105939 - SOP 209.06: Administrative Segregation, Georgia Department of Corrections (2021-01-01) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105940 - Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener), CourtListener (2020-11-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4802501/taylor-v-riojas/ - U.S. Department of Jnstice, U.S. Department of Justice, Civil Rights Division (2013-05-31) [official_report, primary] URL: https://www.justice.gov/sites/default/files/crt/legacy/2013/06/03/cresson_findings_5-31-13.pdf - Williams v. Burton, U.S. Court of Appeals, 11th Circuit, 1991-10-18 (court record via CourtListener), CourtListener (1991-10-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9001576/williams-v-burton/ - Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener), CourtListener (1991-06-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/112626/wilson-v-seiter/