Georgia's Tier Segregation System

The Ladder: Tier I, Tier II, Tier III/SMU and STEP

Georgia's Tier Segregation Management System was implemented in August 2013, described by GDC as a stratification-oriented pathway for an offender to transition out of Administrative Segregation to lower-security levels (per the GDC Tier Management Fact Sheet, [#6593][#20803]). The following year GDC's FY2014 Annual Fiscal Report recorded the only system-wide quantification of what it had built: "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], Georgia's Tier Segregation System collection). That is a bed count from implementation, not a current capacity and not a population — but it establishes the scale as thousands of beds, and it supplies the meaning of the term "Level 5 facility" that SOP 209.08 uses without defining.

Tier I is governed by SOP 209.07, effective 04/30/2015. Its applicability section is deliberately broad: "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]). Tier I is defined as a programme "for the involuntary and voluntary placement and management of offenders in short-term segregated housing," and is capped at 30 days from assignment, "to include investigation and disciplinary isolation time" — with one exception: voluntary and involuntary protective custody are excluded from the cap entirely ([#19249]). The 30-day limit is the only outer time limit anywhere in the adult Tier architecture, and it is disapplied for the category in which a person has least control over their own placement.

Tier II is administrative segregation — the audits use the two terms interchangeably, so the equivalence is established on GDC's own authority ([#19486]). SOP 209.08, effective 04/11/2016, defines it as a "Long Term Administrative Segregation stratification plan" and contains no maximum duration ([#19252]). A person who "cannot return to general population because they pose a serious threat to the safety and security of the institutional operation shall remain in Phase 3," reviewed every 90 days to determine assignment status. Where Tier I is capped at 30 days and Tier III is capped at 24 months, Tier II has no outer limit written into policy at all. The GDC Fact Sheet quoted in 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 the Georgia Diagnostic and Classification Prison ([#19492], [#19491]).

Tier III is the Special Management Unit at Georgia Diagnostic and Classification Prison, governed by SOP 209.09, effective 6/18/2026. Section IV.A.1.a defines it as "a minimum 13 month (390 days) program," requiring a successful offender to spend at least 60 days in E Wing, 60 in F Wing, 90 in D Wing, 90 in C Wing and 90 in B Wing — arithmetic that sums to exactly 390 ([#19260]). Section IV.A.1.f states that offenders "shall not be held in the Tier III Program for more than 24 months," then immediately qualifies it with six retention criteria, including that the offender's crimes "are so egregious that the offender was placed in the Tier III Program immediately upon being placed in GDC custody."

The fourth rung is STEP. GDC wrote two step-down policies on the same day, effective 04/25/2019: SOP 209.45, Tier II STEP, and SOP 209.55, Tier III STEP. Their condition sections are textually near-identical — same four hours out of cell per day, same 15-minute or 25-minute call limits, same two-hour non-contact visits, same thirty-minute checks — with one substantive difference: Tier III STEP provides "All cells are single occupancy," where Tier II STEP provides "Cells may be single or double occupancy" ([#19283], [#19284]). Whether a person in a Georgia step-down unit is held alone or with a cellmate is determined by which Tier they stepped down from.

The load-bearing caveat for everything that follows is stated in the collection's own finding: the Tier label "marks where GDC concentrates long-term administrative segregation programming. It does not mark where segregation cells exist" ([#19512]).

Conditions: What the Ladder Actually Guarantees

Georgia's Tier policies state out-of-cell minimums, and those minimums can be converted into in-cell hours by arithmetic. This is the figure GDC does not publish and the one that matters most. GPS's derivation, from the quoted SOP text, gives 168 hours in a week minus the guaranteed out-of-cell entitlement ([#19272], Georgia's Tier Segregation System collection).

Tier I guarantees "a minimum of five (5) hours per week" of exercise, "with at least one (1) hour per day on five days," leaving two days per week on which the policy guarantees no out-of-cell time at all ([#19270]). That is 163 hours in cell, or 23.3 hours per day on average, and 24 hours on the two days outside the entitlement. Tier II is identical in floor and worse in structure: SOP 209.08 offers "a minimum of five (5) hours per week of exercise," and — unlike Tier I — "specifies no daily distribution. The five hours may lawfully be delivered in any pattern across the week" ([#19269]). Same 23.3 hours per day. Administrative segregation generally, and the juvenile programme RHA-JOAS, sit at the same floor.

The upper rungs are materially different. Tier III guarantees "a minimum of four (4) hours out of cell time per day, Monday through Friday," which produces 20 hours out of cell per week and an average of 21.1 hours per day in cell — with no guaranteed out-of-cell time on Saturdays and Sundays, so the weekend floor is 24 hours ([#19281]). The two STEP programmes guarantee four hours out of cell per day, seven days a week, which produces 28 hours per week out of cell and 20.0 hours per day in cell ([#19283], [#19284]).

The consequence is the sharpest single finding in the collection. Derived from those policy floors, the step-down programmes guarantee 5.6 times more out-of-cell time than Tier II itself (28 hours per week against 5), and Tier III guarantees four times more than Tier II ([#19273]). The stage GDC labels the most restrictive — Tier III, the litigated Special Management Unit — guarantees four times more out-of-cell time than the programme GDC operates across multiple facilities and does not cap.

Set against the UN Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules), whose Rule 44 defines solitary confinement as 22 hours or more a day without meaningful human contact and prolonged solitary confinement as confinement in excess of 15 consecutive days, the arithmetic produces a specific pattern ([#19274], [#19329]). Tier I and Tier II sit inside the 22-hour threshold as a policy floor, every day of the week. Tier III falls below it on weekdays but not on weekends. Both STEP programmes fall below it. On duration: Tier I's 30-day cap is twice the 15-day prolongation threshold and is disapplied for protective custody; Tier II has no cap, and its 90-day review cycle is itself six times the threshold and indefinitely repeatable; Tier III's 390-day minimum is 26 times the threshold, and its 24-month outer limit is roughly 48 times it ([#19329]).

Mandela Rule 44 has a second element, and it is the one Georgia's policies decline to specify. The definition requires both 22 hours or more a day and the absence of meaningful human contact ([#19331]). SOP 209.09 and SOP 209.55 guarantee single occupancy in Tier III and Tier III STEP. SOP 209.45 permits double occupancy in Tier II STEP. SOP 209.08 is silent on occupancy in Tier II, 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 and evaluation within 24 or 48 hours — an implication that multiple occupancy is the ordinary condition ([#19278], [#19279]). SOP 209.08 goes further in drafting: its religious-practice clause refers to offenders praying "in their assigned cells or by their assigned beds," phrasing that only has work to do if some Tier II housing assigns a bed within a shared space rather than a cell of one's own ([#19277]).

GPS's own framing of this is explicit and should travel with the numbers: "Two conditions of confinement are being run in the same programme under the same rules — 23 hours a day alone in a cell, and 23 hours a day locked in a cell with another person — and GDC's Tier II policy distinguishes neither, guarantees neither, and reports neither" ([#19331]). Every other condition in Tier II is similarly modifiable: SOP 209.08 Section IV.D.1.l provides that "all of the above conditions or privileges are subject to modification due to extenuating operational circumstances" at the Warden's discretion, a term the policy does not define, with no time limit, documentation requirement or notice to Central Office ([#19276]). The tablet is confiscated on Tier II placement and returned only at Phase III for education and programming; video visits are capped at one per calendar month ([#19285]).

The Machinery: Placement, Review, Release

Every rung has procedures, and the procedures differ in ways that determine who stays and for how long.

Tier I has eight placement grounds (SOP 209.07, Section I). Only one — awaiting a disciplinary hearing — presupposes a pending charge, and none requires a disciplinary conviction; ground A permits segregation where "the offender is noted as a threat to the safe and secure operation of the Facility," and ground H permits it where the person "has not been classified due to their arrival at a Facility" ([#19248]). The Classification Committee that decides consists of the Unit Manager, the Tier I OIC, the assigned counselor and, as applicable, the assigned mental health counselor — all facility staff, with no external or Central Office member ([#19250]). A formal hearing is held within 96 hours; the counselor reviews well-being every seven days without a formal hearing; the Committee conducts a 30-day review whose outcomes are remain in Tier I, return to general population, or assign to Tier II ([#19250], [#6594]).

Tier II admission rests on criteria the GDC Fact Sheet puts at twelve ([#19492], [#6596]). The broadest one is open on its face: "The offender is noted as a threat to the safe and secure operation of the Facility. This may include, but is not limited to, offenders who have documented STG activities/involvement, notoriety of crimes, high level of supervision requirements, and offenders who have either been threatened with bodily harm or threatened others with bodily harm" ([#19253]). Criteria 1, 5 and 10 can each be satisfied without any disciplinary adjudication. Once placed, the person progresses through Phases 1, 2 and 3 on a 90-day review cycle, with a documented "Phase III+" track for those who complete Phase 3 but remain a security concern ([#19252], [#6597]).

The review structure contains the asymmetry that matters most. Placement is a facility decision: the Warden/Designee approves or disapproves Classification Committee recommendations within seven business days, and in an emergency "the Warden/Designee may authorize the immediate assignment" ([#19256]). Release is a Central Office decision: the exit chain runs Unit Manager recommendation, Warden and Regional Director review, an STG clearance by the Criminal Investigations Unit, then transmission "to the Director of Field Operations who will make the final decision" ([#19256]). A facility can put a person into Tier II on its own authority, including immediately in an emergency, but it cannot take a person out. Worse, the appeal of the 90-day review — the decision that continues confinement — goes only to the Warden/Designee, the same official who approved the placement in the first instance, with no route to Central Office; only the appeal of initial placement reaches the Director of Field Operations ([#19258]). Every subsequent 90-day decision to keep a person in indefinite administrative segregation is therefore reviewed only by the official who authorised the confinement.

Tier III procedures were revamped in SOP 209.09 effective 6/18/2026, and the decision-makers moved. Assignment appeals now go to the Deputy Director, Field Operations, with a final decision by the Director, Field Operations; retention past 24 months requires quarterly review by a four-member panel — the Deputy Director, Field Operations, the Statewide Mental Health Director, the Statewide Medical Director and a member of the Office of Legal Services — plus personal approval by the Director, Field Operations or the Assistant Commissioner for Facilities ([#19261], [#20858]). None of it exists for Tier II.

Running through all of this is a structural fact that explains the absence of a published population figure: no GDC policy requires a Tier population count to be compiled. A review of the 209 series found no SOP naming any Tier roster, periodic report or Central Office aggregate submission; the term "Central Office" does not appear in SOP 209.08 at all ([#19308]). Instead, placements flow upward as individual approvals. GDC does employ a statewide "Tier Segregation Manager" who is advised of release decisions and "shall review the offender's record in SCRIBE" to determine placement — the strongest documentary indication in the SOP corpus that a centralised Tier population record exists ([#19257]).

The records that would establish the population are named in the SOPs themselves. SOP 209.07 and SOP 209.08 both require an Accountability Log recording "cell number, bed number, offender name, offender number, race, in or out time, assignment of offender and destination of offender" — by their own description, a daily record of who is housed in each Tier cell and bed ([#19296]). SOP 209.07 further requires permanent admission and release logs maintained by the officer on duty ([#19296]). And the grievance machinery is deliberately routed away from the placement decision: SOP 227.02 makes "involuntary assignments to Administrative Segregation" non-grievable and 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 that determine whether a person leaves Tier II ([#19319], [#19320]).

Scale: What GDC Publishes, and the Population It Does Not

GDC does publish a Tier III population, but only as a side effect. The Special Management Unit at Jackson appears as a facility row in the monthly Inmate Statistical Profile series' facility population table; as of 2026-09-01 it held 154 people, and across 75 monthly snapshots from 2020-07-01 to 2026-09-01 the SMU population ranged from 149 to 195 ([#19304], [#19376]). Against a stated capacity of 192 beds, the unit has run below capacity throughout the published series ([#19302], [#19484]). This is not a statewide Tier population: it is one facility at Jackson, and it says nothing about Tier I or Tier II, whose units sit inside ordinary prisons and are absorbed invisibly into those prisons' facility totals ([#19304]).

That side-effect figure was, until recently, the only per-facility Tier population GPS held. In October 2026, in response to open-records request R031710-091426, GDC produced a bed table that yielded the first per-facility count of Georgia's Tier II population ([#20768]). On that single undated snapshot, Tier II comprised 8 prisons, 884 beds, 804 occupied (91.0%), and STEP comprised 4 prisons, 119 beds, 96 occupied ([#20762], [#20764]). Tier III comprised 1 location, 160 beds, 128 occupied ([#20757]). All three programmes together: 1,163 beds, 1,028 occupied ([#20765]).

The table covers Tier II, Tier III and STEP only; the request excluded Tier I, disciplinary isolation and protective custody, which GDC operates at every facility — so 1,163 is not a total of Georgia's segregation beds ([#20771]). It also does not split STEP between the Tier II and Tier III versions ([#20854]). And it reports beds, not people: occupied beds are a point-in-time figure, not admissions, lengths of stay, or the number of people who passed through in a year ([#20773]).

What the table shows at facility level: Hancock 83 Tier II beds (82 occupied), Hays 151 (151, 100%), Macon 121 (119), McRae Women's 34 (28), Smith 111 (89), Telfair 117 (117, 100%), Valdosta 129 (80), Ware 138 (138, 100%) ([#20749]–[#20756]). Four of the eight were at or within one bed of full — Hays, Telfair, Ware and Hancock; Valdosta had the most room, 49 of its 129 beds empty ([#20766]). Hays holds the largest restrictive-housing programme outside the SMU: 151 Tier II beds plus 59 STEP beds, 210 in all, every one occupied ([#20767]). McRae Women's Facility is the only women's facility on the list ([#20769]) — and GDC's own public Tier Segregation System fact sheet, still current on 2026-10-05, names only seven facilities, all men's prisons: Hancock, Hays, Macon, Smith, Telfair, Valdosta and Ware ([#19364], [#6595]).

Against those figures, the numbers GDC stopped publishing matter. GDC's FY2018 Annual Fiscal Report stated that "since January 2017, the number of offenders in extended restrictive housing has decreased by 41 percent (671)" ([#19298]); the FY2019 report gave 675 people out of extended restrictive housing, a 40% reduction from the same January 2017 baseline ([#19299]). The two statements are not reconcilable to a single baseline, and in both cases GDC reports a delta with no endpoints — how many people left, never how many remained. Back-solving a baseline from those percentages yields roughly 1,640 or 1,690; those are GPS arithmetic on two inconsistent agency statements and must never be cited as a GDC-published population ([#19299]).

From FY2021 onward, restrictive-housing reporting disappears from the Annual Fiscal Reports as a programme narrative entirely; the only matches in FY2024 and FY2025 are "Special Management Unit" appearing in a list of facilities receiving the NoteActive electronic logbook ([#19303]). The last year in which GDC published any figure about the size or trend of its restrictive-housing population was FY2019. A systematic review of 110 non-monthly GDC reports and all 34 distributions of the monthly Inmate Statistical Profile series found no published count of the Tier or restrictive-housing population; the four near-misses fail specifically because "supervision" reports only Close/Medium/Minimum, "institution_type" reports facility type, "disciplinary" reports disciplinary reports rather than placements, and "mental_health" reports care levels ([#19306]). GDC does not publicly publish current restrictive-housing population counts by tier and facility ([#6608]).

Two further scale indicators survive. The Southern Center for Human Rights' September 2021 class action alleged approximately 300 people in Georgia State Prison's Tier II programme, over 70 percent of them experiencing serious mental illness — an allegation, not a finding, describing a prison that closed on 2022-02-19 ([#19367], [#19369]). And PREA audits record Hays State Prison's Tier I and II units at a stated capacity of 303 Tier beds, and Georgia State Prison at 424 Tier beds including 13 Tier Program dorms — both larger than the entire Tier III Special Management Unit ([#19393], [#19394]).

More recently, SCHR reported that as of October 2025, more than 2,100 people were housed in Georgia's "tiers," including almost 1,000 in the long-term tiers, citing a GDC Tier Management Bed Report obtained via Open Records Act ([#20801], [#20869]). GPS's own open-records precedent strengthens the case for more: GDC has already run and produced a per-facility housing count query when asked ([#19310]).

Per-Facility Scale in the PREA Corpus: Cells Are Not Beds Are Not People

All 273 GDC-published PREA facility audit reports, cycles 1 through 5, were scanned for programme-sense Tier language and segregation-housing counts ([#19514]). They are the best per-facility segregation dataset GDC publishes — and they are internally inconsistent ([#19513]).

A review of all 273 found named Tier programme housing — Tier I, Tier II, Tier III, "Tier Program dorms," "Tier units" — 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]). Of the twelve currently active close-security state prisons, nine have documented Tier programme housing, adding McRae Women's Facility, whose 34-bed Tier II unit appears in GDC's October 2026 bed table ([#19361]). The three close-security prisons whose audits contain no Tier language are Baldwin, Phillips and Augusta State Medical Prison ([#19372], [#19373], [#19361]).

The segregation capacity figures are a separate matter, and they do not track close security. 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], [#19399]). Wilcox State Prison, described in its own audits as housing medium-security general-population inmates, reports 168 segregation cells in Cycle 3, up from 24 double-bunked in Cycle 1 and 72 in Cycle 2 ([#19467], [#19433]). Coffee Correctional Facility, a private medium-security prison, reports 170 ([#19444]). Every state prison in the corpus that reports a number reports segregation cells, close security or medium ([#19511]).

The headline total is a floor: summing the most recent audit per facility that states a count gives 3,401 segregation cells across 30 facilities, or 3,182 across 28 state-operated facilities ([#19398], [#19504]). Four caveats are built into that figure, and GPS states all four. First, it is a cell count, not a bed count and not a population count — the audits themselves distinguish these, and many cells hold two people ([#19398]). Lee State Prison states "16 cells with 32 beds"; Wilcox reports "72 double bunked segregation cells"; Montgomery reports "eight (8) two-man segregation cells"; Macon reports "48 double occupancy cells" ([#19435], [#19433], [#19434], [#19432]). 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 ([#19415]). Third, it mixes vintages — Cycle 2 spans 2017 to 2019, Cycle 3 2019 to 2021, Cycle 4 2021 to 2025 — and the most recent audits of five of the nine Tier prisons dropped the segregation-cell field, so those facilities contribute older numbers ([#19508], [#19416]). Fourth, it counts all segregation, not only Tier programme housing: Tier units are a subset ([#19507]).

The reason for caution is documented. The PREA corpus's own defects, all recorded in GPS's collection, include: Georgia State Prison's "Cycle 3" audit is the Cycle 2 audit republished — both 181 pages, identical after whitespace normalisation, 546,523 characters, zero differences — so its segregation figure must not be counted twice ([#19400], [#19408]); Telfair State Prison's Cycle 4 audit contradicts itself internally, with a form response reading "the facility does not have administrative segregation cells" alongside an interview stating "the facility head reported having 360 administrative segregation beds" ([#19400]); and Pre-Audit Questionnaire segregation fields contradict the same audit's own narrative in at least three cases — Georgia State Prison Cycle 2'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 ([#19411]).

Two further traps are recorded. The word "tier" in a PREA audit usually means the upper or lower gallery of a cellblock, not the Tier programme — phrases like "two tiers of two-man cells" and "a 2 Tier dorm that houses 30 inmates on the top tier" are architectural and are excluded throughout ([#19401], [#19516]). And a single sentence of GDC policy boilerplate about delayed PREA education appears in roughly 60 audits, including audits of facilities that demonstrably have no Tier housing, so a naive keyword search for "Tier Program" produces a badly inflated facility list ([#19402]).

The per-facility counts, each attributed to the audit and cycle that states it, run from Georgia Diagnostic and Classification at 409 segregation cells (Cycle 2) and Smith at 336 down to Long Unit at 4 ([#19438], [#19439], [#19462]). Georgia State Prison's Cycle 2 audit is the fullest description of a Tier II programme in any GDC document GPS holds: "E - North houses 104 offenders in single bunk cells and the South side houses 106 in double bunk isolation/segregation/Tier I Cells"; "Tier II Housing Unit (G Building) houses up to 218 offenders in double bunk cells"; "Tier II (K Building) - Houses 100 inmates in single cell lockdown cells" ([#19473], [#19474], [#19475]). It documents both occupancy modes side by side in the same programme at the same prison — G Building double-bunked, K Building single-cell lockdown ([#19525]) — and records a Tier II progression of "up to two years" that appears nowhere in SOP 209.08 ([#19478]).

Double-bunked segregation and double-bunked Tier housing are not exceptional in Georgia; they are the ordinary described condition at most of the facilities that describe the condition at all ([#19528]). At Hays, the split runs the other way: Tier I units are two-man cells and Tier II units are one-man cells ([#19522]). At Smith, the arithmetic is unambiguous — "48 double bunked cells housing 96 offenders per dorm" ([#19526]). The documented unit capacities run from 20 to 218 per unit; there is no standard Tier dorm size ([#19509]).

Courts, Standards, and the Reform Gap

The Gumm v. Ford settlement of May 7, 2019 imposed a general 24-month limit on SMU confinement, mandatory 60-day or 90-day reviews with out-of-cell mental health evaluations by a licensed professional before assignment and at each review, a bar on housing Mental Health Level III or above prisoners in Tier III/SMU, minimum out-of-cell time, programming, nutrition and sanitation standards, and $425,000 in attorney's fees ([#6641]).

The scope of that relief is the central legal fact about Georgia's Tier system. Every operative settlement term is written in Special Management Unit and Tier III vocabulary; the class arose from conditions in the SMU at Georgia Diagnostic and Classification Prison; and GDC codified the settlement into SOP 209.09 alone ([#19324]). 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. 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. As the collection states it: "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]). A correction GPS has recorded: existing datapoint 6598 describes the Craig Haney expert findings adopted in Gumm as applying to "Tier II/SMU residents," but the inspection and the certified class were the SMU at GDCP, not Tier II, and the Gumm record supplies no findings about Tier II conditions at any facility ([#19325]).

The litigation is not finished. In April 2024 a federal judge found GDC in violation of the settlement agreement, and the case remains subject to ongoing litigation; the same hearing record contains Haney's 2017 finding that 70 of the SMU's 180 inmates were designated mentally ill and that it was "dangerous" to house mentally ill people there ([#7575], [#6606]). A 2024 contempt order found GDC compliance documents "not only insufficient but also unreliable" — that officials falsified documentation ([#1527]).

Wilkinson v. Austin, 545 U.S. 209 (2005), supplies the unusual argument the current architecture invites. The Court held that near-total solitary confinement, indefinite duration, and parole disqualification imposed an "atypical and significant hardship" giving rise to a liberty interest requiring informal procedural protections. The factor Wilkinson identified as central — indefinite duration — is present in Tier II, where SOP 209.08 sets no outer limit, and absent from Tier III, where SOP 209.09 sets a 24-month ceiling with enumerated exceptions and a quarterly panel. On Wilkinson's own reasoning, "the due-process argument is therefore 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.

State rules sit alongside the federal ones. Board Rule 125-3-1-.03 requires a formal Administrative Segregation hearing within 96 hours of involuntary placement with written notice ([#19355]). Board Rule 125-3-2-.10(f) provides that "no confinement to an isolation cell of greater than thirty (30) days shall be imposed without the review and approval of a Division Director of the Department of Corrections" ([#19350]) — and SOP 209.01 Section W caps disciplinary isolation at 30 days in prisons and transitional centres and 14 days in probation detention centres and integrated treatment facilities, designating a Tier II recommendation as the route when isolation time exceeds 30 days ([#19352], [#19292]). That is Tier II written into the discipline policy as the route around the 30-day sanction cap, in a section whose stated premise is a finding of guilt — in direct tension with SOP 209.08's statement that Tier II "is not a punishment measure" ([#19291], [#19292]).

Two policy conflicts remain unresolved in GDC's own rules and are recorded as conflicts rather than resolved. First, medical rounds: SOP 507.04.33 (2022) requires daily rounds in restrictive housing, while SOP 209.07 (2015) and SOP 209.08 (2016) require three visits a week and expressly exclude weekends and holidays. Three visits a week is fewer than half of seven, and the older, less protective standard governs the Tier unit itself ([#19337], [#19336], [#19335]). Second, tablets and visitation: SOP 209.06 (2021) grants administrative-segregation prisoners the same GOAL device and visitation access as general population, while SOP 204.10 (2018) confiscates the device on Tier II placement until Phase III, and SOP 209.08 (2016) limits Tier II visits to one to three non-contact visits per month ([#19286], [#19285]). Both policies claim the field.

A staffing gap runs alongside: SOP 506.08 creates a centrally delivered SMU/Tier III training curriculum, and no corresponding Tier I or Tier II programme — for the multi-site programmes, training is delegated to each Warden, and SOP 209.07's promise that "specialized departmental training will be developed" is written in the future tense in a policy effective in 2015 ([#19290]).

The external route to a Tier population count runs through the Department of Justice. In April 2024 DOJ expanded its CRIPA investigation of Georgia prisons to include restrictive housing, disciplinary practices and special education services. The findings report issued 1 October 2024 addressed only the violence and sexual-abuse prongs; the restrictive-housing findings have not been released ([#19311]). What that report did find bears directly on the subject without being Tier-specific: "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" ([#6607], [#6904]).

The human record behind the procedure is documented. The Gumm court adopted findings, based on Haney's 2017 inspection, that SMU residents were held in cells "smaller than the average parking space," with as little as five hours per week out of cell, no outside light, no congregate programming and frequently locked food-port flaps; Timothy Gumm himself was held continuously for seven and a half years despite fourteen transfer recommendations over four years ([#19326], [#6598]). Haney described the SMU as "one of the harshest and most draconian" he had seen "in decades of conducting evaluations" ([#6624], [#1509]). As of July 2017, 78% of prisoners in the SMU — 141 of 182 — had been held in isolation for more than two years; about 20% had been held six or more years, and the average stay was three to four years ([#1448], [#6609], [#6610]). Thirty-nine percent had a diagnosed mental illness ([#7286]).

Deaths

Solitary confinement's documented harms — psychological deterioration, self-harm, suicide — are not abstractions in Georgia's record. People in solitary confinement, who comprise 6 to 8 percent of the prison population nationally, account for approximately half of all prison suicides ([#5922]). The DOJ's October 2024 findings letter found that segregation can cause severe psychological damage, especially when it involves near-complete isolation and sensory deprivation or extends for a prolonged period ([#20405]).

GPS's death registry names the following people:

• Sherry Elaine Joyce died April 27, 2024, at Arrendale State Prison; the registry lists the cause as Homicide, age 61.
• Hallie Marie Reed died May 5, 2024, at Arrendale State Prison; the registry lists the cause as Homicide, age 23.

Both deaths occurred in the same Lee Arrendale mental health unit, eight days apart, according to the evidence in GPS's women's incarceration collection; that record also notes that Reed had requested protective custody after Joyce's death and was denied ([#5088]).

Beyond those two, the broader mortality picture is documented but incomplete. One thousand forty-two deaths — 56 percent of GPS's mortality registry — still carry no documented cause ([#8392]). In March 2024 GDC stopped providing cause-of-death information in its monthly mortality reports, stating manner of death would be released only after local medical examiners make determinations ([#8120]). A federal judge found in April 2024 that GDC compliance documents relating to SMU conditions were "not only insufficient but also unreliable" ([#1527]), and the contempt litigation cited the suicides of two SMU inmates among people who decompensated in the Tier III programme ([#20411]).

For the Tier system specifically, GDC does not publish the data that would measure this: no suicide or self-harm incidents by tier and facility, no mental health classification breakdown of the Tier II/III population, and no length-of-stay distributions for restrictive housing ([#6669]). That gap is not incidental to the architecture described above. It is a consequence of a system in which every placement travels as a single case, no policy instrument requires anyone to compile a roster, and the last published trend figure for extended restrictive housing is from FY2019 ([#19308], [#19303]).