Solitary Confinement

What Georgia Counts, and What It Does Not

The only Tier population figure GDC publishes is a side effect of bookkeeping. The Special Management Unit at Jackson appears as a standalone facility row in the monthly Inmate Statistical Profile. As of September 1, 2026 it held 154 people; across 75 monthly snapshots from July 2020 to September 2026 it ranged from 149 to 195 [#19304]. Against the unit's stated 192 beds [#19302], and five admissions in FY2025 — 0.06 percent of state-prison admissions [#19305] — that is a stable population GDC documents without ever calling it a Tier count. 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].

Everything else has to be reconstructed. A systematic review of the GDC-published report corpus GPS holds — 110 non-monthly reports and all 34 distribution sections of the monthly Inmate Statistical Profile series — found no published count of the Tier or restrictive-housing population. The four near-misses fail specifically: the 'supervision' field offers only Close, Medium and Minimum; 'institution_type' offers only facility categories; 'disciplinary' reports counts of disciplinary reports rather than sanctions or placements; 'mental_health' reports care levels [#19306]. Because SOP 209.09 classifies every Tier III offender as Close Security, and SOP 209.45 and SOP 209.55 do the same for the STEP populations, the Tier population is contained within GDC's published Close Security count but cannot be isolated from it [#19307]. The published data structure makes the figure arithmetically unrecoverable rather than merely unpublished.

The reason is structural, and GDC's own rules document it. 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. Tier placements instead flow upward as individual approvals, and no policy instrument requires anyone to compile them into a report [#19308]. Yet GDC's own annual fiscal reports state that a dedicated SCRIBE Tier II module went live in March 2019 to track people in extended restrictive housing, and that since FY2020 the SCRIBE Warden's Dashboard displays, for Tier II offenders, 'the number of days an offender has spent in restrictive housing Tier II' [#19300]. The data exists in an electronic system of record; what is missing is a rule requiring anyone to count it.

Two other numbers give the order of magnitude. GDC's FY2014 Annual Fiscal Report states that 2,721 beds were converted to Tier beds at all Level V facilities when the Tier Segregation Management System was implemented — the only system-wide quantification of the Tier system GDC has ever published, and a bed count rather than a population count [#19297, #19417]. Summing the most recent audit figure per facility that states one gives 3,401 segregation cells across 30 facilities, 3,182 across 28 if restricted to state-operated facilities [#19398]. That number is a floor, not a total: it is a cell count rather than a bed or population count, many of those cells hold two people, at least six state facilities with published audits contribute zero because no audit of them states a figure, and the figures span three audit cycles [#19398]. It counts all segregation, not only Tier programme housing [#19507]. Segregation capacity also does not track the Tier designation: the Tier programme label appears only at close-security prisons without exception, but segregation and administrative-segregation housing is documented at medium-security prisons throughout the system, sometimes at larger scale — Calhoun State Prison, a medium-security facility, reports 197 segregation cells, more than close-security Baldwin (167), Ware (125) or Phillips (75), and Dooly's medium-security J2 is a documented 96-person double-bunked administrative segregation unit [#19399, #19511, #19426]. No facility documented as operating Tier programme housing is a women's prison; whether GDC operates a Tier II programme for women is not answered anywhere in the SOP corpus [#19364, #19365].

The disclosure has narrowed over time. GDC published restrictive-housing and Tier programme narratives in its annual fiscal reports in FY2014, FY2017, FY2018, FY2019 and FY2020; from FY2021 the subject disappears [#19303]. The two years it did report a reduction are internally inconsistent: FY2018 describes a 41 percent reduction (671 people) in extended restrictive housing since January 2017, and FY2019 describes a 40 percent reduction (675 people) from the same baseline [#19298, #19299]. Back-solving a baseline from either pair yields roughly 1,640 or 1,690 — GPS arithmetic performed on two inconsistent agency statements, which must never be cited as a GDC-published population figure [#19299]. Note also the shape of the disclosure: GDC reported how many people left and what percentage that was, and never stated the population before or after [#19298].

Three Clocks, and the Arithmetic of a Cell

Georgia runs at least three separate segregation clocks, and the written limits do not run in the direction of the units holding the larger populations. Tier I under SOP 209.07 carries the only firm adult outer limit: 30 days, inclusive of investigation and disciplinary isolation time, with voluntary and involuntary protective custody excepted so the cap is disapplied entirely for people held in protective custody [#19249]. Its out-of-cell floor is five hours per week [#19375], and SOP 209.07 Section II applies it 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' [#19363].

Tier II under SOP 209.08 — which GDC's own fact sheet, quoted in five PREA audits, describes as 'Administrative Segregation' with twelve eligibility criteria, including criterion 5, 'Failure in Tier I or refused to participate' [#19391, #19492] — states no maximum duration at all. The duration figures that exist come from facility audits, not policy: Hays State Prison's Cycle 2 audit 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 progression. None of these appears in SOP 209.08 [#19403, #19494]. Tier III under SOP 209.09 sets a stated minimum of 390 days across five phases and a 24-month ceiling that the Department reserves the right to exceed for six enumerated categories [#19329, #19330]. Retention past 24 months requires quarterly review by a four-member statewide panel — Director of Field Operations, Statewide Mental Health Director, Statewide Medical Director and a member of the Office of Legal Services — plus the personal approval of the Commissioner or Assistant Commissioner for Facilities [#19261]. The same multi-phase architecture is applied to children: SOP 209.11 governs offenders under 18 with the same phase structure, the same visitation ladder and the same moderated-cell cross-reference as Tier II, and provides that on release review a juvenile may be 'Reassigned to the same phase of Tier II as the current Phase of RHA-JOAS, if of age' [#19265].

Measured against the Nelson Mandela Rules, the arithmetic is blunt. Rule 44 defines solitary confinement as confinement for 22 hours or more a day without meaningful human contact, and prolonged solitary confinement as more than 15 consecutive days [#1450]. On GDC's own written minimums, Tier I, Tier II, generic Administrative Segregation and the juvenile programme each impose 23.3 hours in cell per day — 163 of a week's 168 hours — with no guaranteed out-of-cell time on the two non-exercise days. Tier III averages 21.1 hours per day and reaches 24 hours on Saturdays and Sundays. The step-down programmes sit at 20.0 [#19274]. On duration, Tier I's 30-day cap is twice the 15-day threshold; Tier II has none; Tier III's 390-day floor is 26 times the threshold and its 24-month outer limit approximately 49 times it [#19329].

Whether any of this is solitary confinement within Rule 44 turns on a second element — the absence of meaningful human contact — which GDC does not specify for Tier II and does not publish for any facility [#19331, #19404]. SOP 209.09 guarantees single occupancy in Tier III across all five phases; SOP 209.55 does the same for Tier III STEP; SOP 209.45 permits single or double occupancy in Tier II STEP; SOP 209.08 contains no provision on cell occupancy at all, and SOP 209.06 treats single-celling in administrative segregation as an enumerated exception requiring medical, mental-health or classification assignment plus evaluation within 24 or 48 hours [#19278, #19279]. The facility record matches the policy silence: Hancock's G-1 Tier 2 unit houses 'a maximum of 96 inmates, in double occupancy cells located on two tiers'; Georgia State Prison's G Building held up to 218 Tier II offenders in double bunk cells while its K Building held 100 in 'single cell lockdown cells' [#19572, #19474, #19475]. Whether a person is held alone or with a cellmate is determined by which unit they are assigned to, and GDC's Tier II policy neither specifies nor reports it [#19510].

Tier II: The Larger Programme and the Thinner Policy

Tier II is the programme that Gumm v. Ford did not reach. Every operative term of the 2019 settlement is written in Special Management Unit and Tier III vocabulary — a general 24-month limit on SMU confinement, a bar on housing Mental Health Level III or above in Tier III/SMU, 60-day and 90-day mental-health evaluations, the statewide retention panel. GDC codified the settlement into SOP 209.09 alone, revised effective April 23, 2025. SOP 209.08, governing Tier II, contains no duration cap, no mental-health exclusion, no panel, no mental-health evaluation requirement at placement and no out-of-cell minimum beyond five hours per week, and has not been revised since April 11, 2016 — nearly three years before the settlement [#19324]. The protections attached to the unit that was litigated, not to the programme that holds more people [#19324].

The scale comparison is stark, though it rests on an allegation. The Southern Center for Human Rights' September 2021 class action complaint 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 facility that closed on February 19, 2022 [#19367, #6614, #19369]. Against the Special Management Unit's 149-to-195 range across the whole published monthly series, one prison's Tier II programme was roughly twice the size of the entire Tier III programme [#19368]. GPS cannot extrapolate from one facility to a system total and does not. The same prison's Cycle 2 audit separately records 49 Tier II Mental Health Offenders in D East [#19476], 106 double-bunked isolation/segregation/Tier I cells at E-South [#19473], and 424 stated Tier beds across 13 Tier Program dorms [#19394, #19477]. Hays State Prison's Tier I and Tier II units held a stated capacity of 303 — larger than the entire Tier III Special Management Unit [#19393].

The effect written into GDC's own policies is that people with higher mental-health classifications are routed toward the less protected unit. SOP 209.09 excludes both Mental Health Level III and Level IV from Tier III; SOP 209.08 excludes only Level IV and admits Level III on mental-health recommendation [#19254]. SOP 508.01, GDC's mental-health organization policy, places 'Specialized Mental Health Treatment Units (SMHTUs/TIER II, etc.)' in the highest-need tier of its staffing hierarchy alongside death row, the SMU and crisis stabilization, and assigns a minimum of 1.0 FTE mental health counselor per 20 offenders at designated SMHTU/Tier II facilities — the second-richest ratio in the system, behind only crisis stabilization at 1:15 [#19288]. Discipline policy routes people into it: SOP 209.01 caps disciplinary isolation at 30 consecutive days in prisons and transitional centres and 14 days in probation detention centres and integrated treatment facilities, and designates a recommendation for Tier II placement as the route 'if isolation time imposed exceeds thirty (30) days' — in a section whose stated premise is that the offender has first been found to have committed a prohibited act [#19292, #19352]. SOP 209.06 lists among the grounds for Administrative Segregation placement 'Serving sanctions for a violation of Facility/Center rules' [#19293], while GDC's own summary of SOP 209.08 states that the programme 'is not a punishment measure' [#19291].

Procedurally, the exits are narrower than the entrances, and the asymmetry is written into the policy. A facility can place a person in Tier II on its own authority, including immediately in an emergency; release requires a statewide Criminal Investigations Unit clearance and the personal decision of the Director of Field Operations [#19256]. The 24-hour initial administrative-segregation review — which authorises the first 96 hours — 'will not be subject to appeal by the offender'; the appeal that does exist terminates with the Warden, whose 'review and decision on the appeal is final.' There is no neutral or external decision-maker anywhere in the process and no right to counsel or to a non-staff advocate [#19294]. The 90-day review that continues confinement is appealed only to the same Warden who approved the placement in the first instance, with no route to Central Office — unlike initial placement, which does have one [#19258]. And SOP 227.02 prohibits retaliation for filing a grievance but makes 'Involuntary assignments to Administrative Segregation' non-grievable, routing the claim into an appeal that tests whether placement criteria were met and does not test motive [#19319]. The one record that would show a grievance preceded a placement is, by policy, removed from the file and from SCRIBE: 'A Grievance must not be placed in the Offender's file or referred to in SCRIBE case notes' — while SOP 209.08 conditions release from Tier II on the Unit Manager's review of the offender's SCRIBE case notes. A keyword search of SOP 209.08 for 'grievance' returns nothing; the Tier II policy does not mention grievances at all and contains no anti-retaliation provision [#19320].

The Mental Health Record Inside Restrictive Housing

Georgia's own numbers put a diagnosed mentally ill population at the centre of its segregation system. 39 percent of prisoners in the Special Management Unit had a diagnosed mental illness by GDC's own classification [#1449, #6888]. At the 2017 inspection, 70 of the SMU's 180 residents were designated as mentally ill, and Dr. Craig Haney concluded that it was 'dangerous' to house mentally ill people in the SMU [#6606]. Haney described the unit as 'one of the harshest and most draconian' he had seen 'in decades of conducting evaluations,' its residents as 'among the most psychologically traumatized persons [he] ha[d] ever assessed in this context,' and the harm as possibly 'irreversible and even fatal' [#6624]. The Haney report recorded a cell block full of inmates with serious mental illness, a man locked for months inside a pitch-black cell, and another man, naked and psychotic, whose cell was covered in blood [#6643]. The 2024 Gumm court order reviewing settlement compliance documents Haney's finding of 70 mentally ill people among the SMU's 180 [#6606].

The clinical literature is not ambiguous about the mechanism. Grassian's 1983 work identified a 'major, clinically distinguishable psychiatric syndrome' in long-term solitary — hyperresponsivity to external stimuli, perceptual distortions, panic attacks, difficulty with thinking, concentration and memory, intrusive obsessional thoughts, overt paranoia and impulse-control problems [#6623, #7277]. Hagan et al. (2018) found 43 percent of those with solitary-confinement exposure screened positive for PTSD against 16 percent without [#7278]. The American Psychiatric Association's December 2012 position statement, retained in December 2017, opposes prolonged segregation of seriously mentally ill prisoners and defines 'prolonged' as longer than three to four weeks [#6628]; the American Public Health Association in Policy Statement 201310 called solitary 'a public health crisis' and called for an end to long-term use [#6629]; the National Commission on Correctional Health Care recommends prohibiting solitary for seriously mentally ill, juvenile and pregnant individuals and limiting it to under 15 days for everyone else [#6630]. GDC's continued placement of MH-III and MH-IV-classified people in Tier I, Tier II and SMU segregation is, on the record GPS holds, in direct contravention of the APA position [#6887].

Courts have moved unevenly. Madrid v. Gomez held in 1995 that SHU conditions at Pelican Bay violated the Eighth Amendment as applied to prisoners with mental illness, likening prolonged solitary for the mentally ill to 'the mental equivalent of putting an asthmatic in a place with little air to breathe,' while declining to hold long-term SHU confinement unconstitutional for mentally healthy prisoners [#6635, #6876]. Williams v. Secretary Pennsylvania DOC (3d Cir. 2024) held it clearly established that someone with a known preexisting serious mental illness has a constitutional right not to be held in prolonged solitary confinement without penological justification; the court rejected qualified immunity and the U.S. Supreme Court denied certiorari in 2025 [#6636]. Pennsylvania's DRN v. Wetzel settlement required evaluation of all incoming prisoners for serious mental illness, capped restrictive-housing placement for such prisoners at 30 days in 'exceptional' circumstances, required 20 hours per week out of cell, and removed approximately 800 people with serious mental illness from restricted housing units statewide [#6668, #6928]. North Dakota's partnership with Amend at UCSF beginning in 2015 produced a reduction in solitary confinement of more than 74 percent [#4685]. The Eleventh Circuit, which governs Georgia, has not issued a definitive ruling on the constitutional limits of solitary confinement under the Eighth Amendment [#1503].

Georgia's scale is large enough that these standards bear on thousands of people. About 14,000 people system-wide have identified mental health needs, as GDC's Commissioner acknowledged to the 2024 Senate Study Committee [#2873, #7511], and 51.7 percent of the prison population receives mental health outpatient services [#5718]. GDC's own stripped-cell policy recognises that the behaviours which lead to a stripped cell — flooding a cell, smearing or throwing bodily fluids, refusing to be cuffed, setting fires, self-injury — are frequently psychiatric in origin, and requires a clinical determination by the MH/MR team before or in support of the security response [#19386, #19389]. Whether that determination is made and recorded in practice is unknown; the record that would show it is the mental-health evaluation documentation the policy requires for each stripped-cell placement [#19390]. A case file opened in March 2026 illustrates the pattern GPS documents in practice: Christian Yandel Flores Tirado, confirmed MH-3, held in segregation at Georgia Diagnostic and Classification Prison and Rutledge State Prison with documented emotional deterioration [#6911].

Deaths and Self-Harm Inside Isolation

Nationwide, people in solitary confinement comprise 6 to 8 percent of the prison population and account for approximately half of all prison suicides [#5922]; suicide remains a leading unnatural cause of death in custody [#577]. Kaba et al., analysing 244,699 incarcerations in the New York City jail system, found that although only 7.3 percent of admissions involved any solitary confinement, 53.3 percent of self-harm acts and 45.0 percent of potentially fatal self-harm acts occurred within that group; after controlling for length of stay, serious mental illness and demographics, individuals punished with solitary were 6.9 times more likely to commit self-harm [#6625, #6626]. A 2022 follow-up on New York City's adolescent solitary ban found the hazard of self-harm associated with solitary exposure was 1.51 times that of incarcerations with no solitary exposure [#6627].

The Georgia death record inside isolation is named. Justin Waymon Hollingsworth, 43, died by suicide by hanging in segregation at Rogers State Prison on June 26, 2025 [#6909]. Miguel Angel Duran, 44, died by suicide in segregation at Central State Prison on March 1, 2026 [#6908]. Christopher Lee, 19, died at Georgia Diagnostic and Classification State Prison — the facility that hosts the Tier III Special Management Unit — on January 31, 2026, of natural/medical causes, as recorded in the GPS death registry. Two men died by suicide in the Special Management Unit in 2017 [#6603]. Sheqweetta Vaughan, 32, a postpartum mother with documented postpartum depression on psychotropic medication, was found decomposing in segregation cell H-19 at Lee Arrendale State Prison on July 9, 2025; the cell was in the 90s Fahrenheit with minimal ventilation, a neighbouring prisoner reported hearing her call for medical help around 6 a.m. on July 8 — more than 28 hours before she was found — and pathologist Dr. Paul Uribe stated that the decomposition was inconsistent with the required 30-minute welfare checks [#6894]. Jenna Mitchell, a transgender woman held in solitary confinement at Valdosta State Prison, died by suicide on December 6, 2017, after her mother reported suicide threats to the warden; an officer allegedly told her 'OK, what are you waiting for, go for it,' there was a 10-minute delay in cutting her down, and a GDC supervisor allegedly filed a false incident report. Her family settled for $2.2 million on December 6, 2021 [#6774]. The Southern Center for Human Rights' 2021 complaint alleged at least 12 suicides at Georgia State Prison between September 2019 and May 2021 — nearly 30 percent of all GDC suicides in that window — an allegation, not a finding [#19328].

Deaths in restrictive housing are not always self-inflicted. In February 2023, an incarcerated person was found dead in his restrictive-housing cell at Calhoun State Prison, wrapped in mattress padding, with the coroner describing the cell as a mess. No one had entered the cell for two days; staff had shut off the water supply and closed the chow flap. Cause of death: dehydration with renal failure [#6655, #6902]. Jimmy Lucero deteriorated mentally at Wilcox State Prison, was not provided services, was placed in solitary, and died at Augusta State Medical Prison in June 2016 from a pulmonary embolism from a deep vein thrombosis consistent with prolonged fasting and starvation; a $550,000 settlement was reached in 2019 [#6796]. James Wheeler, with a history of self-harm, was placed in solitary at Wilcox State Prison and hanged himself in October 2017; a $750,000 settlement was reached in 2021 [#6798]. Demitri Carter died by suicide at Phillips State Prison in October 2017 after multiple prior attempts; a $700,000 settlement was reached in 2021 [#6799]. Among the people placed in solitary after other victimization, the Department of Justice found that queer and transgender prisoners reported being placed in solitary confinement after reporting sexual assault or other violence, or because they were experiencing mental health crises — making solitary a punitive response to victimization and vulnerability [#1536].

How complete any of this is cannot be established from what GDC publishes. GDC has not publicly disclosed suicide and self-harm incidents by tier and facility, mental-health classification breakdowns of the Tier II/III population, or length-of-stay distributions for restrictive housing [#6669]. GDC's screening standard is thin by its own terms: SOP 219.01 requires that Tier I offenders 'should be asked' about suicidal thoughts a minimum of once per month, and Tier II offenders during weekly rounds — and Tier I placement is capped at 30 days, so a person can serve an entire Tier I term and be asked about suicidal ideation exactly once. The unit with the shorter maximum stay carries the less frequent screening requirement, and the verb is permissive: 'should be asked,' not 'shall be asked' [#19287]. The check records themselves are the subject of an express prohibition against falsification: SOP 209.07 forbids batch entries, stating that the 30-minute checks 'should be documented when they occur, not at the end of the shift ("gang" entries shall never be permitted on any of the Tier I Segregation/Isolation forms)' — a prohibition whose existence is evidence that the practice was known [#19346, #19349].

Litigation, the Standards Gap, and the Records That Would Settle It

Gumm v. Ford is the only sustained federal litigation Georgia's Tier system has produced, and its reach is limited. The case began in February 2015 as a handwritten pro se complaint by Timothy Gumm, who was held in the SMU continuously for seven and a half years despite fourteen transfer recommendations over four years [#19321, #19326, #6612]. The May 7, 2019 settlement 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 mental health 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, sanitation and reading-material access, and documentation and reporting requirements, with $425,000 in attorney's fees [#6641]. The district court found the relief necessary to prevent violations of constitutional rights, narrowly tailored, and the least intrusive means of ensuring compliance with minimal constitutional requirements [#19326]. People were released directly from the SMU to the community at sentence expiration with no transitional programming [#6677].

Compliance has not followed. On April 19, 2024, Chief Judge Marc T. Treadwell found that GDC had 'no desire or intention' to comply with the December 2018 settlement and ordered an independent monitor, fines of $2,500 per day — $75,000 every 30 days for six months — and additional attorney's fees, extending the settlement past its initial three-year term. The order documents that officials falsified therapy records, including recording that a man attended treatment sessions after he was already dead [#19322, #6803]. SCHR's representative told the 2024 Georgia Senate Study Committee that a federal judge had found violation of the settlement in April 2024 and that the case is subject to ongoing litigation [#7575].

What the litigation did not do is settle the constitutional question for Tier II. Wilkinson v. Austin held in 2005 that Ohio's supermax conditions — near-total solitary confinement of indefinite duration plus parole disqualification — imposed an 'atypical and significant hardship' giving rise to a Fourteenth Amendment liberty interest requiring informal, non-adversary procedural protections, and the Court did not reach the Eighth Amendment [#19327]. 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 a named decision-maker, a named form and a fixed quarterly review interval. On Wilkinson's own reasoning the due-process argument is therefore stronger for Tier II than for the programme the litigation actually reformed — but this is an argument from a holding, not a holding: no court has applied Wilkinson to Georgia's Tier II programme, and no court has made a finding that Georgia uses Tier placement to retaliate for protected activity [#19327, #19312]. GPS's case-law corpus returns nothing for retaliatory segregation in Georgia, but the corpus is post-conviction and habeas weighted and does not hold section 1983 conditions litigation, so its silence is not itself evidence of absence [#19312]. Likewise, no Supreme Court ruling directly addresses whether solitary confinement is constitutional; the Court denied certiorari in Hope v. Harris [#1584].

The most likely external source of a Tier population count is still pending. 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, #6661]. The findings report issued October 1, 2024 addressed only the violence and sexual-abuse prongs — finding 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,' and that the lack of out-of-cell time in restrictive housing violated constitutional standards [#19311, #4816]. The restrictive-housing findings have not been released [#19311]. GPS should treat that absence as a live, dated gap rather than as evidence either way [#19311]. In the meantime, the records exist and are named. The Tier II SCRIBE module and the Warden's Dashboard's 'number of days an offender has spent in restrictive housing Tier II' field should be requested by name; the Accountability Log required by SOP 209.06, 209.07 and 209.08 is a same-day, cell-by-cell, bed-by-bed census of each Tier unit printed daily by policy; the segregation admissions and releases register yields both population and length of stay; and the quarterly over-24-month Tier III panel reviews and Commissioner approvals yield the number held past the ceiling [#19309]. GDC has already demonstrated it will run and produce a per-facility housing count query: open-records 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].