Prison conditions
Holding cages and restraint in Georgia prisons
Use of holding cages and restraint in Georgia prisons.
Where this research is used
This page is a research collection: individual facts drawn from the sources listed further down, each traced to where it came from. A research topic brings many collections together into one overview of an issue. The facts on this page feed these 4 topics; open one to see how they fit with the rest of the evidence.
Facility Conditions & Infrastructure
Georgia's prison system is a physically failing estate: buildings averaging more than 30 years old, a maintenance record in which the state's own auditors found that funding availability — not need — drove repairs, and a documented pattern of doors that do not lock, plumbing that does not carry waste, and housing that does not cool. Two state-commissioned studies and a federal civil rights investigation agree on the diagnosis. They disagree sharply on how overcrowded the system actually is, because Georgia publishes at least four different capacity figures for the same prison. This page sets out what the record shows about the physical plant, what the state has committed to spend on it, and what remains undocumented.
12,892 data points
Oversight & Accountability
Georgia runs one of the nation's largest prison systems with no independent body empowered to inspect it, no ombudsman outside the Department of Corrections, and no public reporting requirement attached to the $600 million it has been voted for prison spending. A six-year federal civil rights investigation found constitutional violations across the system in October 2024 and recommended 82 remedial measures; more than 230 days after its 49-day litigation deadline expired, no one had been arrested, fired, or sued as a result. What remains is a closed loop in which the department investigates its own deaths, codes its own mortality data, disciplines — or does not discipline — its own staff, and classifies its investigative files as confidential state secrets.
20,251 data points
Solitary Confinement
Georgia runs a Tier Segregation System whose written rules guarantee as little as five hours out of cell per week, impose no outer time limit on its largest long-term program, and have never been paired with a published count of how many people are inside it. The one unit that was litigated — the Special Management Unit at Georgia Diagnostic and Classification Prison — was reformed by a 2019 settlement and then held in contempt in April 2024; the larger Tier II program, governed by a policy last revised in 2016, received none of those protections. What the Department of Corrections does publish, together with court orders, its own auditors' findings and the names in GPS's death registry, describes a system that holds people for years, concentrates mental illness inside it, and does not count its dead by housing unit.
2,672 data points
Violence & Safety
Georgia's prison system kills people at a rate that federal investigators found unconstitutional, and then undercounts the dead. A 93-page Department of Justice findings report released October 1, 2024 concluded that the State of Georgia and the Georgia Department of Corrections violate the Eighth Amendment by failing to protect incarcerated people from violence and sexual abuse, describing 'near-constant life-threatening violence as the norm.' The documented record — 142 homicides reported from 2018 through 2023, more than 1,400 violent incidents in a 16-month window, 456 sexual abuse allegations in a single year with 35 substantiated — rests on the Department's own numbers, which the Department itself misreports.
12,020 data points
Key Findings
The most impactful data from this research collection. Tap a card for the full finding and its source.
The finding
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.
The finding
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.
The finding
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.
The finding
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.
The finding
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.
The finding
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.
The finding
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.
All Data Points
89 verified data points extracted from primary sources.
Rogers State Prison: six weeks without shower or outside recreation in segregation-related conditions Case detail
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.
SMU solitary confinement cell dimensions Finding
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.
Lawsuit: Ramirez placed in outdoor rec cell at 86 degrees after mental health meeting Case detail
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.
Hays State Prison: assaulted man held naked in suicide-watch cell without mattress or blanket Case detail
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.
Stokes v. Johnson: one day in shower not Eighth Amendment violation Legal fact
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.
Williams v. Burton: continued force after resistance ceases can violate Eighth Amendment Legal fact
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.
Lawsuit: nurses found Ramirez naked on concrete near vomit and excrete about 3 p.m. Case detail
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.
Rogers State Prison: people held in kiosks and shower cages up to a week when segregation cells unavailable Case detail
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.
Stokes v. Johnson: court silent on 3-day shower detention Legal fact
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.
Braggs v. Dunn definition of segregation: 22.5+ hours per day in cell Legal fact
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.
Bibiano v. Garrett: joint motion to stay pending settlement (August 2025) Legal fact
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.
Ware State Prison: nearly a year without a mattress; blocked from bathroom and defecated in pants Case detail
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.
SOP 209.07: 96-hour Tier I classification hearing requirement Policy
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.
Braggs v. Dunn: suicidal prisoners placed in unsafe crisis cells Finding
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.
Bibiano v. Garrett: plaintiff filed motion for settlement approval (October 2025) Legal fact
In Bibiano v. Garrett, the plaintiff filed a motion for settlement approval in October 2025.
Rule 125-3-2-.10: hourly recorded inspection for close observation in Disciplinary Isolation Legal fact
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.
SOP 209.07: medical round schedule in Tier I segregation Policy
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.
Braggs v. Dunn: exercise 'cages' barely larger than segregation cells Finding
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.
Sims v. Mashburn: magistrate found 29 hours in undershorts in concrete box justified relief Legal fact
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.
Rule 125-3-2-.10: two-hour checks, three meals, and unlimited water in Disciplinary Isolation Legal fact
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.
Gilmore v. GDC: en banc Eleventh Circuit strip-search ruling Legal fact
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.
DOJ: Parchman holds suicidal prisoners in non-suicide-resistant holding tanks Finding
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.
Sims v. Mashburn: Eleventh Circuit doubted such harm meets Eighth Amendment threshold Legal fact
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.
Rule 125-3-2-.10: 30-day isolation cap without Division Director review; 60 days for single-incident series Legal fact
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.
McClinton v. Warden: Eleventh Circuit affirms on failure-to-protect Legal fact
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.
DOJ: Parchman close custody is 23 hours/day lockdown Finding
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.
Sims v. Mashburn: Eleventh Circuit reversed judgment against officer for cell stripping Legal fact
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.
SCHR: Valdosta State Prison holding cages telephone-booth sized, no toilets, sinks, or beds Finding
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.
GDCP Special Management Unit bed count Statistic
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.
192 beds
DOJ: Parchman restrictive housing average 515 days Statistic
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.
515 days
Chandler v. Crosby: Eighth Amendment objective component requires 'extreme' condition Legal fact
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.'
SCHR: 13 of 15 interviewees saw people held in VSP cages from two days to three weeks Statistic
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.
13 of 15 interviewees
SMU outdoor yard: twice-weekly standing in small cage Finding
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.
Nunez Monitor: Rikers intake toilet overflowing with feces, person sleeping on floor Finding
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.
Chandler v. Crosby: Eighth Amendment requires assessing severity and duration of heat/ventilation exposure Legal fact
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.
SCHR: man held in E2 kiosk cage multiple days after suicidal ideation; urinated in bottles, defecated on trays Case detail
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.
SOP 209.06: 30-minute documented checks in administrative segregation Policy
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.
Nunez Monitor: Rikers intake conditions imploded, people held days or weeks Finding
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.
SCHR demands GDC stop housing people in VSP holding cages more than a few hours Finding
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.
SOP 507.04.35: definition of a Stripped Cell Policy
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).
Taylor v. Riojas: six days in feces-covered cell unconstitutional Legal fact
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.
SCHR: VSP F1 cell without working sink or toilet for two to three days in April 2025 Case detail
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.
Atlanta Transitional Center holding cell limit: 8 hours Policy
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.
Taylor v. Riojas: feces packed in water faucet, inmate did not eat or drink four days Case detail
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.
SOP 209.04: water offered at least every two hours in Safety Restraint Chair Policy
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.
Atlanta Transitional Center Unit 1 temporary holding cells Finding
A PREA audit report on the Atlanta Transitional Center describes Unit 1's first floor as having 2 Temporary Holding Cells.
Taylor v. Riojas cites Hope v. Pelzer on obvious cruelty providing notice Legal fact
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.
SOP 209.04: fifteen-minute checks documented on Segregation/Isolation Checklist Policy
GDC's Safety Restraint Chair policy requires fifteen-minute checks to be completed and documented on the Segregation/Isolation Checklist.
AJC: SMU phased system and exercise pen twice a week Finding
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.'
Hope v. Pelzer: hitching post beyond order restoration violates Eighth Amendment Legal fact
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.
SOP 209.04: hourly review, two-hour chair limit without Warden authorization, two-hour health reassessment Policy
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.
Juan Carlos Ramirez Bibiano death at Telfair State Prison Case detail
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.
Hope v. Pelzer: Larry Hope handcuffed to hitching post about seven hours Case detail
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.
SOP 209.04: bathroom break offered every two hours after initial two-hour span Policy
GDC's Safety Restraint Chair policy requires a bathroom break to be offered every two hours after the initial two-hour time span.
Ramirez lawsuit: left in outdoor recreation cage Case detail
GPB reported that the lawsuit says Ramirez 'was not inside but rather outside, left in what are commonly called outdoor recreation cages.'
Hope v. Pelzer: general constitutional rule may apply with obvious clarity Legal fact
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.
SOP 209.04: bathroom opportunity at least once every two hours, documented in logbook Policy
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.
Ramirez lawsuit: five hours in outdoor cell before medical attention Case detail
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.'
Hope v. Pelzer cites Farmer v. Brennan on inferring deliberate indifference from obvious risk Legal fact
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.
SOP 209.05: stripped cell observation at least every 15 minutes, documented and signed Policy
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.
Coleman v. Brown: MHCB transfer wait times, September 2016 Statistic
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.
448 class members vs. 86.5 average wait time (hours)
Hope v. Pelzer quotes Rhodes v. Chapman on pain without penological justification Legal fact
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.
SOP 209.05: stripped cell is a cooling-off period ordinarily no more than eight hours Policy
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.
Coleman v. Newsom: plaintiffs' objection to TTMs Legal fact
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.
SCHR: Valdosta prisoners held days or weeks in telephone-booth-sized cage without water, toilet, mattress Finding
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.
SOP 209.05: continued stripped-cell confinement requires medical and Warden authorization; 72-hour report Policy
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.
Coleman v. Newsom: defendants' position on TTMs Legal fact
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.
Rhodes v. Chapman: Eighth Amendment prohibits unnecessary and wanton infliction of pain Legal fact
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.
Brooks v. Warden: Deputy Warden Powell denied qualified immunity for unsanitary confinement Legal fact
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.
DOJ SCI Cresson: restraint chair durations for prisoners with SMI Finding
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.
Wilson v. Seiter: conditions claims require inquiry into official's state of mind Legal fact
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.
Brooks v. Warden: shackled man forced to soil himself during three-day hospital stay after SMU riot Case detail
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.
DOJ SCI Cresson: prisoner KK restraint chair near 24 hours Case detail
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.
Wilson v. Seiter: required state of mind in prison-conditions cases is deliberate indifference Legal fact
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.
Brooks v. Warden: Brooks held in SMU at GDCP; Eighth Amendment claims against four officials Case detail
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.
DOJ SCI Cresson: self-harm response and six days without mattress Case detail
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.
Farmer v. Brennan: deliberate indifference requires subjective awareness of risk Legal fact
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.
SOP 508.28: Observation Cells serve safety and temporary holding functions Policy
GDC's policy on managing potentially suicidal, self-injurious and assaultive offenders states the primary functions of Observation Cells are safety and temporary holding.
DOJ SCI Cresson: ~23 hours/day isolation for prisoners with SMI Finding
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.
Farmer v. Brennan: two requirements for Eighth Amendment violation Legal fact
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.
SOP 508.28: fifteen-minute watch minimum and 24-hour limit before Warden notification Policy
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.
Jensen v. Shinn: treatment in telephone booth-like cage in restraints Finding
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.'
Hudson v. McMillian: core inquiry is whether force applied maliciously and sadistically Legal fact
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.
Lawsuit: Georgia State Prison solitary cells infested with rats and roaches, waste accumulates Case detail
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.
Jensen v. Shinn: recreation cages roughly cell-sized Finding
The Jensen v. Shinn order states those individual recreation cages are 'roughly the same size as a cell.'
Lawsuit: Juan Carlos Ramirez died after five hours in Telfair cage, heat index 105 Case detail
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.
Lawsuit: at least 12 suicides at Georgia State Prison in two years before filing Statistic
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.
12 suicides
Jensen v. Shinn: strip search and restraints before treatment cage Finding
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.
Jensen v. Shinn: treatment cage 'obviously inhospitable' Finding
The Jensen v. Shinn order states 'the treatment cage is "obviously inhospitable" and it makes it "difficult" for a' prisoner.
Sources
39 cited sources backing this research.
Primary
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Secondary
Journalism
Primary
Legal document
Secondary
Journalism
Primary
Legal document
Primary
Legal document
Primary
Legal document
Primary
Legal document
Primary
Legal document
Primary
Official report
Primary
Legal document
Primary
Legal document
Primary
Legislation
Primary
Official report
Primary
Official report
Primary
Official report
Primary
Official report
Primary
Legal document
Primary
Legal document
Primary
Press release
Primary
Official report
Primary
Legal document
Primary
Official report
Secondary
Journalism
Secondary
Journalism
Primary
Official report
Primary
Official report
Primary
Legal document
Primary
Legal document
Primary
Legal document
Secondary
Journalism
Secondary
Journalism
Primary
Legal document
Primary
Official report
Primary
Legal document
Primary
Official report
Primary
Legal document
Key Entities
Organizations, people, facilities, and other named entities referenced in this research.
Alabama Department of Corrections
[organization]
Atlanta Transitional Center
[facility]
Baldwin State Prison
[facility]
Bibiano v. Garrett
[case]
Braggs v. Dunn
[case]
Brooks v. Warden
[case]
Carl Humphrey
[person]
Chandler v. Crosby
[case]
Clarissa Gilmore
[person]
Coleman v. Brown
[case]
Coleman v. Newsom
[case]
DOJ Civil Rights Division
[organization]
Eleventh Circuit
[organization]
Farmer v. Brennan
[case]
Fred Dalton Brooks
[person]
Georgia Board of Corrections
[organization]
Georgia Department of Corrections
[organization]
Georgia Department of Corrections SOP 209.07
[legislation]
Georgia Department of Corrections SOP 507.04.35
[legislation]
Georgia Diagnostic and Classification Prison
[facility]
Georgia State Prison
[facility]
Gilmore v. Georgia Department of Corrections
[case]
Hardie Vertrain Sims, Jr.
[person]
Hays State Prison
[facility]
Hope v. Pelzer
[case]
Hudson v. McMillian
[case]
James McMillan
[person]
Jensen v. Shinn
[case]
John B. Sanderson
[person]
Juan Carlos Ramirez
[person]
Juan Carlos Ramirez Bibiano
[person]
June Bishop
[person]
Kilby Correctional Facility
[facility]
Larry Hope
[person]
McClinton v. Warden, Baldwin State Prison
[case]
Mississippi State Penitentiary (Parchman)
[facility]
Norma Bibiano
[person]
Nunez Independent Monitor
[organization]
Nunez v. City of New York
[case]
Ramirez
[person]
Rhodes v. Chapman
[case]
Ricardo McClinton
[person]
Rikers Island
[facility]
Rogers State Prison
[facility]
Rule 125-3-2-.10
[legislation]
SCI Cresson
[facility]
Sims v. Mashburn
[case]
Smith State Prison
[facility]
SOP 209.04
[organization]
SOP 209.05
[legislation]
SOP 209.06
[organization]
SOP 508.28
[organization]
Southern Center for Human Rights
[organization]
Special Management Unit
[facility]
Stokes v. Johnson
[case]
Supreme Court of the United States
[organization]
Taylor v. Riojas
[case]
Telfair State Prison
[facility]
Trent Taylor
[person]
U.S. Department of Justice
[organization]
United States v. Lanier
[case]
Ware State Prison
[facility]
William Powell
[person]
Williams v. Burton
[case]
Wilson v. Seiter
[case]