Georgia's Tier Segregation System

The ladder: Tier I, Tier II, Tier III/SMU and the STEP programmes

Georgia's Tier Segregation Management System was implemented statewide in August 2013 (#6593). The only system-wide quantification GDC has ever published for it appears in the FY2014 Annual Fiscal Report: "Developed and implemented the Tier Segregation Management System at all Level V facilities. As part of this system, 2,721 beds were converted to Tier beds" (#19297). That is a bed count describing beds converted at implementation — not a current capacity, not a count of people — but it establishes the system was built at a scale of thousands, not hundreds, and it supplies the meaning of "Level 5 facility" in SOP 209.08, which refers to the class without defining or naming it (#19263).

Tier I is short-term segregation and it is authorised everywhere. SOP 209.07, effective 04/30/2015, applies to "All State Prisons, County CIs, Private Prisons, Intensive Treatment Facilities, Transitional Centers, Probation Detention Centers, and Probation Boot Camp housing GDC offenders or probationers" (#19247, #19363). Hays State Prison's Cycle 2 audit describes Tier I as "short-term segregation/30 days"; Telfair's Cycle 2 audit says Tier I offenders "are housed up to 30 days and then released to general population or assigned to Tier II" (#19494, #19495). Tier II is long-term administrative segregation. SOP 209.08, effective 04/11/2016, defines it as a "Long Term Administrative Segregation stratification plan" and contains no maximum duration at all — offenders who "cannot return to general population because they pose a serious threat" remain in Phase 3, reviewed every 90 days to determine whether they stay (#19252). A fact sheet GDC itself published, quoted in five PREA audits, describes Tier II as "Administrative Segregation" with twelve eligibility criteria, including criterion 5, "Failure in Tier I or refused to participate," and criterion 11, "Transfer from Georgia Diagnostic and Classification Prison" (#19391, #19487, #19488). Refusal to participate in Tier I is thus itself a ground for long-term administrative segregation, and so is arriving from GDCP.

Tier III is the Special Management Unit. SOP 209.09, effective 04/23/2025, makes it a minimum 13-month (390-day) programme: at least 60 days in E-Wing, 60 in F-Wing, and 90 each in D-, C- and B-Wing, five phases from most to least restrictive, and a stated ceiling — "Offenders shall not be held in the Tier III Program for more than 24 months" (#19260). The STEP programmes are the fourth rung, and GDC classifies them out of the restrictive-housing category entirely: SOP 209.45 and SOP 209.55 each state affirmatively that the STEP programme "is not a restrictive housing unit" (#19333). That carve-out is operationally significant — it will exclude the step-down population from any GDC production framed on the term "restrictive housing" (#19309).

The tension inside GDC's own rules is documented. SOP 209.08's summary says the Tier II programme "is not a punishment measure" (#19291). SOP 209.01, the discipline policy, caps disciplinary isolation at 30 consecutive days in prisons and transitional centres and 14 days in probation detention centres and integrated treatment facilities — and then designates the Tier II recommendation as the route when isolation time exceeds 30 days (#19352, #19292). Tier II is written into the discipline SOP as the mechanism for continuing confinement past the sanction cap, in a section whose stated premise is a finding of guilt (#19292). Separately, SOP 209.08 Section IV.B criterion 1 — "The offender is noted as a threat to the safe and secure operation of the Facility. This may include, but is not limited to..." — is open-ended on its face: no evidentiary standard, no requirement of a disciplinary conviction, and it expressly covers a person who "ha[s] been threatened with bodily harm," i.e. a victim rather than an aggressor (#19253).

The one number GDC publishes: 154 in the Special Management Unit

GDC does publish a Tier III population, but only as a side effect of the SMU being carried as a standalone facility with its own GDC facility code. The Special Management Unit at Jackson appears as a facility row in the monthly Inmate Statistical Profile's facility population table; as of 2026-09-01 it held 154 people (#19304). Across 75 monthly snapshots from 2020-07-01 to 2026-09-01 the SMU population ranged from 149 to 195 (#19304, #19376). Its capacity is stated as 192 beds, matching GDC's own description of six cellblocks of single-bunked cells (#19302, #19484). Because SOP 209.09 requires all Tier III cells to be single occupancy, the SMU cell count and bed count coincide there — which is not true anywhere else in the Tier system (#19302). Against 192 beds, a population of 154 implies the unit has run below its bed capacity throughout the published series (#19304). Admissions into it are tiny and must not be read as Tier III intake: FY2025 recorded 5 admissions, 0.06 percent of state-prison admissions, a figure that counts people admitted to GDC custody directly at the SMU rather than transfers in from other prisons, which is how most people reach it (#19305).

Everything else about the Tier population is unpublished. A systematic review of 110 non-monthly GDC reports and all 34 distribution sections of the monthly Inmate Statistical Profile series found no published count of the Tier or restrictive-housing population (#19306). The Daily Population by Facility / Average Daily Population report consists of eleven facility-TYPE rows and three columns, with no facility, no security level, no housing type and no segregation status; all 22 editions are structurally identical (#19306). None of the 34 monthly distributions reports segregation, restrictive housing or Tier status, and the four near-misses fail specifically: "supervision" offers only Close, Medium and Minimum; "institution_type" offers only facility types; "disciplinary" reports counts of disciplinary reports, not sanctions or placements (#19306). The eleven GDC Annual Fiscal Reports from FY2014 to FY2025 contain restrictive-housing and Tier programme narratives in FY2014, FY2017, FY2018, FY2019 and FY2020 — and from FY2021 onward the subject disappears as a programme narrative (#19303). The last year in which GDC published any figure about the size or trend of its restrictive-housing population was FY2019; there is no published figure, percentage or trend for the five reporting years FY2021 to FY2025 (#19303).

The invisibility is structural, and it is documented from GDC's own rules. SOP 209.09 Section IV.A.2 classifies all Tier III offenders as Close Security, and SOP 209.45 and SOP 209.55 do the same for the STEP populations (#19262). The monthly profile's only housing-adjacent field is "supervision," reporting Close, Medium and Minimum — so the Tier population is contained inside GDC's published Close Security count and cannot be isolated from it (#19307). The published data structure makes the Tier population arithmetically unrecoverable rather than merely unpublished. On top of that, no policy requires anyone to compile it: a review of the 209 series found no SOP naming any Tier roster, periodic report or Central Office aggregate submission, and the term "Central Office" does not appear in SOP 209.08 at all (#19308). Placements flow upward as individual approvals — for Tier II from Classification Committee to Warden with notice to the Regional Director, release requiring the Director of Field Operations (#19308).

The data nonetheless exists. GDC's FY2019 report says the "TIER 2 SCRIBE module went live March 2019 to effectively track offenders in Extended Restrictive Housing," and FY2020 describes a Warden's Dashboard field for "number of days an offender has spent in restrictive housing Tier II" (#19300). A single statewide "Tier Segregation Manager" is named in SOP 209.08 and "shall review the offender's record in SCRIBE" — a position that necessarily holds a statewide view of Tier placements (#19257). GDC's own reduction figures, meanwhile, do not reconcile: FY2018 states that since January 2017 the number of offenders in extended restrictive housing "has decreased by 41 percent (671)"; FY2019 states 40 percent (675) against the same January 2017 baseline, while the FY2018 Commissioner's letter attributes the 41 percent to FY2018 alone (#19298, #19299). Back-solving a baseline from those pairs yields roughly 1,640 and roughly 1,690 people — that is GPS arithmetic performed on two inconsistent agency statements and must never be cited as a GDC-published population figure (#19299).

What the PREA audits show — and why the total is a floor

All 273 GDC-published PREA facility audit reports in the GPS index, Cycles 1 through 5, were scanned for programme-sense Tier language and for segregation-housing counts, with every figure attributed to the audit that states it (#19514). Named Tier programme housing — Tier I, Tier II, Tier III, "Tier Program dorms," "Tier units" — appears in the audits of exactly nine facilities: Georgia State Prison, Smith, Hays, Valdosta, Telfair, Macon, Hancock, Georgia Diagnostic and Classification State Prison, and Ware. All nine are close-security prisons. There is not one exception in 273 documents (#19359, #19360). The nine are the seven designated Tier I and II facilities plus Georgia State Prison (closed 2022-02-19) and GDCP, which hosts Tier III (#19359, #19369).

Summing the most recent audit per facility that states a count gives 3,401 segregation cells across 30 facilities; restricting to state-operated facilities gives 3,182 across 28 (#19398, #19504). Four caveats travel with that number. First, it is a CELL count, not a bed count and not a population — the audits themselves are explicit that many of these cells hold two people: Lee State Prison states "16 cells with 32 beds," Wilcox "72 double bunked segregation cells," Montgomery "eight (8) two-man segregation cells," Macon "48 double occupancy cells" (#19398, #19435, #19434, #19432). The bed count is materially higher and the number of people is a separate unknown that GPS has not interpolated and should not. Second, it is a floor: at least six state facilities with published audits contribute zero because no audit of them ever states a figure — Arrendale (three audits), Augusta State Medical Prison (four), Walker (five), Helms Facility, Emanuel Unit, and McRae Women's Facility, which has no audit in the corpus under that name (#19415, #19374). Third, it mixes vintages: Cycle 2 (2017–2019), Cycle 3 (2019–2021) and Cycle 4 (2021–2025), and the most recent audits of five of the nine Tier prisons — GDCP, Hays, Smith, Macon and Wilcox — dropped the segregation-cell field, so those facilities contribute older numbers (#19508, #19416). Fourth, it counts all segregation, of which Tier units are only a subset (#19507).

Per-facility, as each facility's own audit states it: GDCP 409 cells (Cycle 2), Smith 336, Telfair 280, Hays 252, Hancock 223, Macon 192, Coffee Correctional Facility 170 (private), Wilcox 168 (Cycle 3), Baldwin 167, Valdosta 161, Ware 125 (#19397, #19438, #19439, #19440, #19441, #19437, #19443, #19444, #19433, #19445, #19446, #19447). The pattern that matters is that segregation capacity does not track close security even though the Tier designation does (#19399, #19485). Calhoun State Prison, whose Cycle 2 audit gives its security level as "4/Medium," reports 197 segregation cells — more than close-security Baldwin (167), Ware (125) or Phillips (75) (#19442, #19530, #19399). Wilcox, described in its own audits as housing medium-security general population, reports 168 in Cycle 3, up from 24 double-bunked in Cycle 1 and 72 in Cycle 2 (#19433, #19467). Coffee, a private medium-security prison, reports 170 (#19444). Dooly, medium security, reports 71 in Cycle 3, and its Cycle 4 audit describes housing unit J2 as "designated housing of Administrative Segregation, Isolation and Mental Health Observations ... 96 inmates in double bunks in a cell setting" (#19451, #19426, #19532). Johnson State Prison's J-1 and J-2 are "an administrative segregation unit" holding 72 and 94 offenders (#19425).

The corpus is the best per-facility segregation dataset GDC publishes, and it is internally inconsistent (#19513, #19400). Nine categories of defect are recorded (#19400). Georgia State Prison's "Cycle 3" audit is the Cycle 2 audit republished — both 181 pages, 546,523 characters of extracted text, identical after whitespace normalisation, both dated 2019-03-22, so its segregation figure must not be counted twice (#19408). Emanuel Women's Facility's Cycle 5 audit is published twice, identically (#19409). Telfair's Cycle 4 audit contradicts itself in the same report: "The PCM indicated the facility does not have administrative segregation cells," against "Through the interview process the facility head reported having 360 administrative segregation beds" (#19400). Pre-Audit Questionnaire fields contradict the same audit's narrative in at least three cases: Georgia State Prison's questionnaire says 12 segregation cells while its narrative itemises 106 Tier I cells at E-South, 218 Tier II beds at G Building and 100 Tier II single lockdown cells at K Building; Telfair's says 280 against a described isolation and segregation unit of "40 single cells and 40 double-bunked cells"; Hancock's says 320 against "J Building - Tier 1/Segregation ... There are 20 cells in the unit" (#19411). Label defects leave the unit of measure undetermined — Washington Cycle 3 reads "Number of segregation/isolation units 48" where 48 is implausible as housing units; Dooly Cycle 3 reads "Number of segregation/isolation 71" with the noun missing; Pulaski's "1" is not comparable to a cell count and is excluded (#19413). Georgia State Prison Cycle 2's security-level field reads "Minimum" while the same report's narrative states "This is a close security institution" (#19405). Any published GPS figure drawn from this corpus must name the facility, the cycle and the field, and must not silently reconcile a questionnaire figure against a narrative one (#19513, #19400). Two further traps: the word "tier" in an audit usually means the upper or lower gallery of a cellblock, not the Tier programme (#19401, #19516), and one sentence of GDC policy boilerplate about delayed PREA education that mentions "Tier Program" appears in roughly 60 audits, including transitional centres and county institutions with no Tier housing (#19402, #19515).

Occupancy and the arithmetic of solitary confinement

Within one system, GDC has written an express single-occupancy guarantee into Tier III and Tier III STEP, an express permission to double-occupy into Tier II STEP, and nothing at all into Tier II (#19278). SOP 209.08 imposes no single-occupancy requirement, and SOP 209.06 Section IV.G treats single-celling in Administrative Segregation as an enumerated exception requiring assignment by medical, mental-health or classification staff plus evaluation within 24 or 48 hours — the necessary implication being that multiple occupancy is the ordinary condition (#19279, #19404). SOP 209.08's religious-practice clause lets offenders pray "in their assigned cells or by their assigned beds," phrasing that only has work to do if some people in Tier II housing are assigned a bed inside a shared space rather than a cell of their own (#19277).

The audits describe what the policy does not. Hancock's G-1 "Tier 2" unit, in identical words across Cycles 2 and 3, houses "a maximum of 96 inmates, in double occupancy cells located on two tiers" — the clearest single documentary confirmation that Georgia's long-term administrative segregation programme is operated as double-celled confinement (#19572). Hancock's J Building: "Tier 1/Segregation inmates are housed in double occupancy cells. There are 20 cells in the unit" (#19573, #19428). Smith State Prison's Cycle 4 audit, onsite from 2025-02-03, states "This dormitory houses a maximum of 192 Tier 1 offenders (96 on each side)" and the same for Tier 2, in "48 double bunked cells housing 96 offenders per dorm" (#19427, #19526). Ware's J-Building holds 100 Tier 1 offenders, double bunked, 50 per side (#19429). Telfair's Tier I offenders are "housed in E-1 and E-2. E-1 houses 80 inmates and E-2 houses 70 inmates in two man cells," alongside an isolation/segregation unit of 40 single and 40 double-bunked cells (#19430, #19469). Georgia State Prison ran both occupancy modes inside the same programme: Tier II at G Building double-bunked at up to 218, Tier II at K Building "100 inmates in single cell lockdown cells," plus 106 double-bunk Tier I cells at E-South and 49 "Tier II Mental Health Offenders" at D East (#19474, #19475, #19473, #19476, #19525). Hays split the other way — Tier I units in two-man cells at 64, Tier II units in one-man cells at 32, across a stated 303 Tier beds (#19471, #19470, #19522, #19393). Documented unit capacities run from 20 to 218; there is no standard Tier dorm size (#19509). The structural pattern is arithmetic: a unit of a given number of cells holds that number of people when single-bunked and twice that number when double-bunked, and Smith is the clearest case (#19526). Georgia State Prison's 424 stated Tier beds was more than twice the Special Management Unit's 192 (#19394, #19524, #19302). Those figures are historical: Georgia State Prison closed 2022-02-19 (#19369).

The out-of-cell floor is the other half of the definition. At five hours per week, a person is in cell 163 hours per week — 23.3 hours per day (#19272). Mandela Rule 44's definition of solitary confinement has two elements: confinement for 22 hours or more a day, AND the absence of meaningful human contact (#19331, #1476). GPS can establish the first element for Tier I and Tier II by arithmetic from GDC's own written minimums, and cannot establish the second, and must not assume it (#19331). Where a Tier II cell is single-occupancy, both elements may be satisfied and Rule 44 engaged; where the cell is double-bunked, the person is in cell 23.3 hours a day but is not without human contact in the Rule 44 sense (#19331). The honest framing is that whether a person in Georgia's Tier system is held alone or with a cellmate — and therefore whether a 23-hour-a-day confinement counts as solitary confinement — is determined by which unit they are assigned to, and GDC's Tier II policy neither specifies nor reports it (#19331, #19510, #19274). Set against the Mandela Rules' 15-day prolongation threshold: Tier I's 30-day cap is twice it and is disapplied for protective custody; Tier II has no cap; Tier III's 390-day minimum is 26 times it and its roughly 730-day outer limit is approximately 48 times it (#19329). The Tier III SOP's own conditions call for four hours out of cell Monday through Friday and no guaranteed weekend out-of-cell time, averaging 21.1 hours in cell per day — below the 22-hour threshold on weekdays, at 24 hours on Saturdays and Sundays (#19281, #19272).

Two operational findings sit alongside this. GDC's 2023 internal audits found severe lapses in staff and supervisor rounds in segregation units in at least nine prisons; at one medium-security men's prison the audit found long gaps between checks and some days with no checks at all, and noted that all check sheets the auditor reviewed were incomplete (#2621). GDC's Tier II and Tier I inspection schedules themselves exclude weekends and holidays for health care officials, the Chief of Security, the Unit Manager and the Deputy Warden; only the Institutional Duty Officer is required daily, and the Tier II SOP's medical round is three times per week excluding weekends and holidays (#19340, #19341, #19336), in conflict with the Health Services SOP 507.04.33's daily-rounds requirement (#19337, #19334). At Calhoun State Prison, a person was killed by his cellmate in segregation after an officer had reported the two should not share a cell; the DOJ separately documented a prisoner in restrictive housing at Calhoun found dead after no one entered his cell for two days, the door flap locked shut, water off and no meals delivered, with cause of death dehydration with renal failure (#2643, #124).

The settlement reformed the smaller programme

The Gumm v. Ford settlement of May 7, 2019 imposed a general 24-month limit on SMU confinement, barred housing anyone at Mental Health Level III or above in Tier III/SMU, required 60-day or 90-day reviews with out-of-cell mental health evaluations by a licensed professional before assignment and at each review, set requirements for out-of-cell time, programming, nutrition, sanitation and reading materials, and provided $425,000 in attorney's fees (#6641). The certified class was the Special Management Unit at the Georgia Diagnostic and Classification Prison — a single facility — and GDC codified the settlement into SOP 209.09 alone (#19324). The current Tier III SOP carries the ceiling, the mental-health exclusion, the evaluations, a quarterly four-member panel of the Director of Field Operations, the Statewide Mental Health Director, the Statewide Medical Director and a member of the Office of Legal Services, and personal approval by the Commissioner or Assistant Commissioner for Facilities to hold anyone past 24 months (#19324, #19261).

SOP 209.08, governing Tier II, has none of it, and has not been revised since 2016-04-11 — nearly three years before the settlement (#19324). No duration cap. No mental-health exclusion. No panel. No mental-health evaluation requirement at placement. No out-of-cell minimum beyond five hours per week (#19324). The protections won in Gumm attached to the unit that was litigated, and to no other part of the Tier system. The programme with the least protection is the larger one (#19324). The Tier II duration figures that do appear in the record appear only in audits and nowhere in the SOP: Hays Cycle 2 calls Tier II "long-term segregation/270 days"; Macon's Cycle 2 and Cycle 4 audits describe it as running "from nine months to indefinite" and "from 270 days to an indefinite date"; Georgia State Prison's Cycle 2 audit records "up to two years" for Tier II progression — none of which has any basis in SOP 209.08 (#19403, #19418, #19496, #19497, #19478). The mental-health routing runs the same direction: SOP 209.09 excludes both MH Level III and Level IV from Tier III, while SOP 209.08 excludes only Level IV and admits Level III on mental-health recommendation — so prisoners with the higher classifications are routed away from the reformed unit and remain eligible for the one whose policy floor is five hours per week (#19254). The September 2021 Southern Center for Human Rights complaint against Georgia State Prison alleged approximately 300 people in that prison's Tier II programme, over 70 percent of them experiencing serious mental illness; that is an allegation in a complaint, not a finding, and it describes a facility that closed on 2022-02-19 (#19367, #19228 [sic: #19328], #19369).

Wilkinson v. Austin, 545 U.S. 209 (2005), held that near-total solitary confinement, indefinite duration and parole disqualification imposed an atypical and significant hardship giving rise to a Fourteenth Amendment liberty interest requiring informal, non-adversary procedural protections, without reaching the Eighth Amendment (#19327). The factor the Court identified as central — indefinite duration — is present in Tier II, where SOP 209.08 sets no outer limit, and absent from Tier III, where a ceiling with enumerated exceptions exists. On Wilkinson's own reasoning, the due-process argument is stronger for Tier II than for the programme the litigation actually reformed (#19327). That is an argument from a holding, not a holding; no court has applied Wilkinson to Georgia's Tier II programme (#19327).

Even Tier III's ceiling is qualified in the sentence that follows it. SOP 209.09 states the 24-month limit and then reserves the right to retain offenders longer if one of six criteria is met — the last being that the offender, "due to unique position of influence and authority over others, poses such an exceptional, credible, and articulable risk to the safe operation of the prison system or to the public that no facility other than the Tier III Program facility is sufficient to contain the risk" (#19330, #19260). The safeguards against that override are real: quarterly review using a named form against eight criteria including the mental-health evaluation and total duration in the SMU, a four-member statewide panel, and Commissioner-level personal approval (#19330, #19261). But the limit operates as a presumption subject to override rather than as a cap — while no named decision-maker, form, review interval or panel exists anywhere in Tier II (#19330).

The grievance route runs the other way. SOP 227.02 prohibits retaliation for filing a grievance but lists "Involuntary assignments to Administrative Segregation" and housing and security classifications as non-grievable, routing the remedy into the SOP 209.06 classification appeal, which tests whether placement criteria are met and not motive, and which terminates with the Warden, whose decision "is final" (#19319, #19294, #8015). The same SOP requires that a grievance "must not be placed in the Offender's file or referred to in SCRIBE case notes" — while SCRIBE case notes are among the records SOP 209.08 conditions Tier II release on (#19320). The first 96 hours of segregation rest on a 24-hour decision the policy makes unappealable (#19294). The asymmetry in the release chain is written into the policy: a facility can put a person into Tier II on its own authority, including immediately in an emergency, but release requires a statewide Criminal Investigations Unit clearance and the personal decision of the Director of Field Operations (#19256). The 90-day review that continues confinement is appealed only to the Warden — the same official who approved the placement (#19258). No document in GPS's holdings establishes that Georgia's Tier programmes are used to retaliate against people who file grievances or contact lawyers; no court has made such a finding, and GPS's case-law corpus is post-conviction and habeas weighted, so its silence is not itself evidence of absence (#19312). GPS's internal retaliation coding schema has no Tier value, collapsing Tier I, Tier II, Tier III, disciplinary isolation and administrative segregation into a single code (#19313).

The missing designation document, who it leaves out, and the records path

The seven-facility Tier I and II designation — Hancock, Hays, Macon, Smith, Telfair, Valdosta and Ware — derives from GDC fact sheets of which GPS holds the 2018 and 2019 editions, archived at the Digital Library of Georgia (#6595, #19366). It should be cited as GDC's designation as of 2018–2019, not as the current set (#19366). Material changes have occurred since: Georgia State Prison at Reidsville, which the Southern Center for Human Rights' September 2021 complaint identified as running a Tier II programme of approximately 300 people, closed on 2022-02-19 (#19367, #19369, #19366); SOP 209.09 was revised effective 2025-04-23 (#19371); and SOP 508.01, effective 2023, refers to "designated SMHTU/TIER II facilities" without naming them (#19370). No SOP in the corpus lists the designated facilities: neither SOP 209.08, 209.09, 209.45, 209.55 nor 209.11 contains an applicability section naming them, a keyword search of the 1,432-document GPS SOP corpus returns nothing, SOP 209.08 refers to "Level 5 facilit[ies]" without defining the term, and SOP 508.01 refers to designated Tier II facilities without naming them (#19264). The current facility designation document is the single most load-bearing missing document for the question of Tier's system-wide scale (#19264).

The designation is also exclusively male. All seven designated facilities are men's prisons; GDC's two close-security-classified women's facilities, McRae Women's Facility and Arrendale State Prison (Mixed Close/Medium), are not on the designation list (#19364). On the documented record, the Tier II programme as designated operates only in men's prisons (#19364). The Tier SOPs themselves are written in gender-neutral terms and SOP 209.07 applies Tier I system-wide, so women in GDC custody are subject to Tier I segregation (#19364, #19363). Whether GDC operates a Tier II programme for women, and if not, what long-term segregation mechanism applies to them, is not answered anywhere in the SOP corpus or in the published fact sheets GPS holds (#19365). McRae Women's Facility has no PREA audit in the corpus under that name, and the facility is not in the GPS inmate database — a blind spot that compounds the gap (#19374, #5075). Of the 273 PREA audit reports, only two women's facilities contribute a segregation-cell figure at all: Emanuel Women's Facility 7 cells (Cycle 3) and Whitworth Women's Facility 7 cells (Cycle 4) (#19459, #19460).

The DOJ route is pending and should be treated as a live dated gap. In April 2024 the Department of Justice expanded its Civil Rights of Institutionalized Persons Act investigation of Georgia prisons to include restrictive housing, disciplinary practices and special education services (#19311). The findings report issued 1 October 2024 addressed only the violence and sexual-abuse prongs; the restrictive-housing findings have not been released (#19311). A CRIPA findings report on restrictive housing would ordinarily contain population, duration and per-facility figures obtained by compulsory process, which is why it is the most likely external source of a Tier population count (#19311). What the October 2024 letter did find, bearing on Tier but not Tier-specific, is that "GDC fails to control violence even in its segregated housing units and exposes incarcerated persons to an unreasonable risk of harm due to its inappropriate use of segregated housing" (#19311).

The records that would settle it are named in GDC's own policy, which is why they are requestable. The Accountability Log required by SOP 209.07 Section VI.K and SOP 209.08 Section IV.P.6 records "cell number, bed number, offender name, offender number, race, in or out time, assignment of offender, and destination of offender" and is printed daily after 1800 hours — a same-day, cell-by-cell, bed-by-bed census of each Tier unit (#19296, #19309). Division Director approvals for isolation beyond 30 days, required by Board Rule 125-3-2-.10(f), would give a floor on long-stay isolation independent of any Tier population figure (#19350, #19351). The quarterly over-24-month Tier III panel reviews and the Commissioner's personal approvals would yield the number held in Tier III beyond 24 months (#19309, #19261). The SCRIBE Tier II module (live March 2019) and the Warden's Dashboard's days-in-restrictive-housing field should be named explicitly in any request, because GDC's own annual reports establish both exist (#19300, #19309). GDC has already demonstrated it will run and produce a per-facility housing count query: GPS request R024615-101925 asked for a current count of inmates by security designation at each state prison and GDC produced per-facility count tables (#19310). No GPS open-records request has yet asked for Tier or segregation population data — of 43 GDC requests in the registry, none is segregation-related (#19310). One obstacle is recorded: SOP 219.01 asserts that offender records are confidential state secrets under O.C.G.A. § 42-5-36(c), so a request framed around individual records will meet that exemption while a request framed around aggregate counts, unit rosters stripped of names, and designation and capacity documents will not (#19296). GPS's own publication record has the same hole: a keyword search for "Tier II" across all published GPS posts returns zero results, and GPS has published extensively on retaliation and conditions without ever publishing on the Tier system (#19316).