GPS RESEARCH LIBRARY: Solitary Confinement & Restrictive Housing ============================================================ Georgia Prisoners' Speak — gps.press Generated: 2026-03-07 03:54:21 EST Research Date: 2026-01-01 JSON: https://gps.press/research/solitary-confinement-restrictive-housing/?format=json SUMMARY ---------------------------------------- Georgia's Special Management Unit represents one of the most extreme examples of prolonged solitary confinement in the United States, with 78 percent of its 182 prisoners held in isolation for more than two years as of July 2017, despite overwhelming scientific evidence that solitary confinement causes severe psychological harm. The Georgia Department of Corrections has systematically violated a 2019 settlement agreement designed to improve conditions, prompting a federal court to impose $2,500 daily fines beginning May 2024 after finding "flagrant" violations and discovering that compliance documents had been falsified. This pattern of non-compliance occurs against a backdrop of catastrophic understaffing—approximately 50 percent vacancy rates agency-wide and exceeding 70 percent at Georgia's ten largest facilities—creating conditions where vulnerable prisoners are housed in shower stalls, denied basic hygiene, and left without adequate medical response to treatable injuries. The concentration of harm in Georgia's system mirrors national trends documented across the prison population. Fifty percent of all prison suicides occur among the approximately 6 to 8 percent of prisoners held in solitary confinement, yet 39 percent of Georgia's SMU population had diagnosed mental illness. Researchers have documented that 91 percent of solitary confinement prisoners report anxiety, 77 percent report chronic depression, and 70 percent report an impending nervous breakdown. Individuals with mental illness in solitary are approximately seven times more likely to self-harm than those in the general population. A June 2025 meta-analysis synthesizing data from 171,300 inmates found significantly greater psychological distress and psychiatric symptoms, including self-harm and thought disorders, among those in solitary confinement. The practice also perpetuates racial disparities: Black individuals comprise 38 percent of the Federal Bureau of Prisons population but 59 percent of Special Management Unit placements, while Black women comprise only 22 percent of the female prison population but 42 percent of women in solitary. Georgia's resistance to reform, despite court orders and DOJ findings, reflects a broader national struggle over solitary confinement policy. While approximately 25 states introduced restrictive housing legislation between 2018 and 2020, and seven states enacted reforms in 2021 alone—with Connecticut, Nevada, New York, and New Jersey establishing 15 to 20-day maximum limits aligned with United Nations Mandela Rules—Georgia remains among the most punitive jurisdictions. The Eleventh Circuit, which governs Georgia, has issued no definitive ruling on solitary confinement's constitutional limits, creating legal uncertainty. Named individuals like Timothy Gumm, held 7.5 years in the SMU despite 14 transfer recommendations, and Johnny Mack Brown, confined for 9 years, exemplify the indefinite isolation that violates international standards establishing 15 days as the maximum threshold before solitary constitutes torture. The gap between court orders and on-the-ground compliance demands urgent investigation. GPS should obtain current SMU population data, independent monitor reports filed since April 2024, and staffing figures at Georgia Diagnostic and Classification Prison to assess whether conditions have actually improved. Cross-referencing mortality databases with housing assignments could establish Georgia-specific correlations between solitary placement and suicide risk. The DOJ's October 2024 findings report containing 82 recommendations and the subsequent contempt order suggest potential litigation or consent decree—tracking the trajectory of federal enforcement action is critical to understanding whether meaningful systemic change will follow. STATISTICS (35) ---------------------------------------- - [confirmed] Prison suicides concentrated in solitary confinement population 50% of prison suicides occur among people in solitary confinement, who comprise only 6–8% of the total prison population. Value: 50 percent of prison suicides (vs. 6–8 percent of total prison population in solitary) Tags: solitary confinement, suicide, mortality, mental health, disproportionality Sources: The Psychological Effects of Solitary Confinement: A Systematic Critique - [confirmed] Percentage of Georgia SMU prisoners held more than 2 years 78% of prisoners (141 of 182) in Georgia's Special Management Unit had been held in isolation for more than 2 years as of July 2017. Value: 78 percent Date: 2017-07-01 Tags: Georgia, SMU, duration of isolation, solitary confinement, GDC Sources: Gumm v. Jacobs litigation filings - [confirmed] Percentage of Georgia SMU prisoners with diagnosed mental illness 39% of prisoners in Georgia's Special Management Unit had a diagnosed mental illness, despite the well-documented harm isolation inflicts on mental health. Value: 39 percent Tags: Georgia, SMU, mental illness, solitary confinement, GDC Sources: Gumm v. Jacobs litigation filings - [confirmed] Daily fines imposed on GDC for contempt A federal court imposed daily fines of $2,500 ($75,000 per month) on the Georgia Department of Corrections starting May 20, 2024, for a period of 6 months, after finding 'flagrant' violations of the settlement agreement governing SMU conditions. Value: 2500 dollars per day (vs. 75000 dollars per month) Date: 2024-05-20 Tags: GDC, contempt, fines, Gumm v. Jacobs, federal court, accountability Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] GDC staffing vacancy rate approximately 50% The DOJ found an approximately 50% staffing vacancy rate across the Georgia Department of Corrections, with critical understaffing making even basic prisoner escorts impossible, contributing to deaths from treatable injuries. Value: 50 percent vacancy rate Date: 2024-10-01 Tags: GDC, staffing, vacancy, understaffing, DOJ investigation Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] GDC staffing vacancy rate greater than 70% at 10 largest facilities The DOJ found staffing vacancy rates greater than 70% at the 10 largest GDC facilities. Value: 70 percent vacancy rate Date: 2024-10-01 Tags: GDC, staffing, vacancy, understaffing, DOJ investigation, largest facilities Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] Washington State 2024 study: 50% clinically significant depression/anxiety/guilt A 2024 Washington State study randomly sampled 106 prisoners in long-term solitary and administered the Brief Psychiatric Rating Scale (BPRS), finding clinically significant depression, anxiety, and guilt in 50% of participants. Value: 50 percent of participants with clinically significant symptoms Date: 2024-01-01 Tags: Washington State, BPRS, depression, anxiety, solitary confinement, clinical study Sources: Washington State 2024 study on long-term solitary confinement - [confirmed] Haney symptom prevalence: 91% anxiety in solitary Dr. Craig Haney documented that 91% of prisoners held in solitary confinement reported anxiety in his study sample. Value: 91 percent reporting anxiety Date: 2003-01-01 Tags: Craig Haney, anxiety, solitary confinement, symptom prevalence Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Haney symptom prevalence: 86% oversensitivity to stimuli in solitary Dr. Craig Haney documented that 86% of prisoners held in solitary confinement reported oversensitivity to stimuli. Value: 86 percent reporting oversensitivity to stimuli Date: 2003-01-01 Tags: Craig Haney, oversensitivity, solitary confinement, symptom prevalence Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Haney symptom prevalence: 83% social withdrawal in solitary Dr. Craig Haney documented that 83% of prisoners held in solitary confinement reported social withdrawal. Value: 83 percent reporting social withdrawal Date: 2003-01-01 Tags: Craig Haney, social withdrawal, solitary confinement, symptom prevalence Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Haney symptom prevalence: 77% chronic depression in solitary Dr. Craig Haney documented that 77% of prisoners held in solitary confinement reported chronic depression. Value: 77 percent reporting chronic depression Date: 2003-01-01 Tags: Craig Haney, depression, solitary confinement, symptom prevalence Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Haney symptom prevalence: 70% impending nervous breakdown in solitary Dr. Craig Haney documented that 70% of prisoners held in solitary confinement reported an impending nervous breakdown. Value: 70 percent reporting impending nervous breakdown Date: 2003-01-01 Tags: Craig Haney, nervous breakdown, solitary confinement, symptom prevalence Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Haney symptom prevalence: 68% heart palpitations in solitary Dr. Craig Haney documented that 68% of prisoners held in solitary confinement reported heart palpitations. Value: 68 percent reporting heart palpitations Date: 2003-01-01 Tags: Craig Haney, heart palpitations, physical symptoms, solitary confinement Sources: Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003 - [confirmed] Self-harm rate 7x higher for mentally ill in solitary vs. general population Individuals with mental illness in solitary confinement are approximately 7 times more likely to self-harm than those in general population. Value: 7 times more likely to self-harm Tags: self-harm, mental illness, solitary confinement, risk factor Sources: The Psychological Effects of Solitary Confinement: A Systematic Critique - [confirmed] Racial disparity: Black individuals 38% of BOP but 59% of SMU placements Federal Bureau of Prisons data from 2022 shows Black individuals constituted 38% of the total BOP population but 59% of Special Management Unit placements. Value: 59 percent of BOP SMU placements (Black individuals) (vs. 38 percent of total BOP population (Black individuals)) Date: 2022-01-01 Tags: racial disparity, Black, BOP, SMU, solitary confinement, federal prisons Sources: Federal Bureau of Prisons SMU placement data, 2022 - [confirmed] Racial disparity: White individuals 58% of BOP but 35% of SMU placements Federal Bureau of Prisons data from 2022 shows White individuals made up 58% of the total BOP population but only 35% of Special Management Unit placements. Value: 35 percent of BOP SMU placements (White individuals) (vs. 58 percent of total BOP population (White individuals)) Date: 2022-01-01 Tags: racial disparity, White, BOP, SMU, solitary confinement, federal prisons Sources: Federal Bureau of Prisons SMU placement data, 2022 - [confirmed] Racial disparity among women: Black women 42% of solitary but 22% of female population According to Liman Center data, Black women comprised 42% of women in solitary confinement but only 22% of the total female prison population. Value: 42 percent of women in solitary (Black women) (vs. 22 percent of total female prison population (Black women)) Tags: racial disparity, Black women, gender, solitary confinement, Liman Center Sources: Liman Center Census, Yale Law School - [estimated] Estimated U.S. solitary population 2014: 80,000–100,000 In 2014, the estimated number of people in solitary confinement in the United States was 80,000–100,000. Value: 80000–100000 people in solitary Date: 2014-01-01 Tags: national population, solitary confinement, United States, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [estimated] Estimated U.S. solitary population 2016: ~68,000 In 2016, the first Liman Center census estimated approximately 68,000 people in solitary confinement in the United States. Value: 68000 people in solitary Date: 2016-01-01 Tags: national population, solitary confinement, United States, Liman Center, first census Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] U.S. solitary population 2019: 31,542 in 39 reporting states In 2019, 31,542 people were held in restrictive housing, representing 3.8% of 825,473 prisoners across 39 reporting states. Value: 31542 people in restrictive housing (vs. 3.8 percent of 825,473 prisoners in 39 reporting states) Date: 2019-01-01 Tags: national population, solitary confinement, restrictive housing, Liman Center, 2019 census Sources: Liman Center/CLA Census data, Yale Law School - [estimated] Estimated U.S. solitary population 2021: 41,000–48,000 In 2021, the estimated number of people in solitary confinement in the United States was 41,000–48,000; the pandemic may have increased use. Value: 41000–48000 people in solitary (estimated) Date: 2021-01-01 Tags: national population, solitary confinement, COVID-19, pandemic, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] 2019 solitary duration: 46% held 3 months or less Of the 31,542 people held in restrictive housing in the 2019 census, 46% had been held for 3 months or less. Value: 46 percent held 3 months or less Date: 2019-01-01 Tags: duration, solitary confinement, restrictive housing, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] 2019 solitary duration: 11% held more than 3 years (~3,000 people) Of the 31,542 people held in restrictive housing in the 2019 census, 11% (nearly 3,000 people) had been held for more than 3 years. Value: 11 percent held more than 3 years (vs. 3000 approximate number of people) Date: 2019-01-01 Tags: duration, long-term, solitary confinement, restrictive housing, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Over 3,000 prisoners with serious mental illness in solitary across 33 states (2019) Across 33 reporting states in 2019, over 3,000 prisoners with serious mental illness were held in solitary confinement. Value: 3000 prisoners with serious mental illness in solitary Date: 2019-01-01 Tags: mental illness, solitary confinement, national data, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Solitary use rate ranges from 0% to 11% by state The rate of solitary confinement use ranged from 0% to 11% of the total prison population depending on the state, with four states reporting that they held no one under restrictive housing conditions. Value: 0–11 percent of total prison population Date: 2019-01-01 Tags: state variation, solitary confinement, restrictive housing, Liman Center Sources: Liman Center/CLA Census data, Yale Law School - [estimated] Legislative reform acceleration: ~25 states introduced bills 2018–2020 Between 2018 and 2020, legislators in approximately 25 states introduced bills to limit restrictive housing, with about 15 states enacting legislation. Value: 25 states introducing bills (vs. 15 states enacting legislation) Date: 2020-01-01 Tags: legislative reform, restrictive housing, state legislation Sources: Liman Center/CLA Census data, Yale Law School - [estimated] Since 2020: bills introduced in ~30 state legislatures Since 2020, bills addressing solitary confinement have been introduced in roughly 30 state legislatures. Value: 30 state legislatures with bills introduced Date: 2020-01-01 Tags: legislative reform, restrictive housing, state legislation Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Seven states enacted solitary legislation in 2021 In 2021 alone, seven states enacted legislation addressing solitary confinement: Arkansas, Colorado, Connecticut, Kentucky, New York, North Carolina, and Tennessee. Value: 7 states enacting legislation in 2021 Date: 2021-01-01 Tags: legislative reform, 2021, Arkansas, Colorado, Connecticut, Kentucky, New York, North Carolina, Tennessee Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] HALT Act implementation: 40% held beyond allowed period (April 2024) An April 2024 contempt ruling found that 40% of individuals in solitary under the HALT Act had been held longer than the law allows. Value: 40 percent held beyond legal limit Date: 2024-04-01 Tags: New York, HALT Act, contempt, implementation failure, compliance Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] HALT Act implementation: 24% held without sufficient evidence An April 2024 contempt ruling found that 24% of individuals in solitary under the HALT Act were held without sufficient evidence meeting the evidentiary standard. Value: 24 percent held without sufficient evidence Date: 2024-04-01 Tags: New York, HALT Act, contempt, evidentiary standard, compliance Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] SMU population July 2017: 182 prisoners As of July 2017, 182 prisoners were held in Georgia's Special Management Unit. Value: 182 prisoners in SMU Date: 2017-07-01 Tags: Georgia, SMU, population, 2017 Sources: Gumm v. Jacobs litigation filings - [confirmed] SMU duration: 44% held more than 4 years (July 2017) As of July 2017, 44% (80 of 182) of prisoners in Georgia's SMU had been held for more than 4 years. Value: 44 percent held more than 4 years Date: 2017-07-01 Tags: Georgia, SMU, duration, long-term isolation Sources: Gumm v. Jacobs litigation filings - [confirmed] SMU duration: 26% held more than 5 years (July 2017) As of July 2017, 26% (47 of 182) of prisoners in Georgia's SMU had been held for more than 5 years. Value: 26 percent held more than 5 years Date: 2017-07-01 Tags: Georgia, SMU, duration, long-term isolation Sources: Gumm v. Jacobs litigation filings - [disputed] GDC claimed 40% reduction in restrictive housing population since 2017 As part of the 2019 settlement, GDC claimed a 40% reduction in the restrictive housing population since 2017. Value: 40 percent reduction claimed Date: 2019-01-01 Tags: GDC, restrictive housing, population reduction, claim Sources: Gumm v. Jacobs litigation filings - [confirmed] DOJ report contained 82 recommendations The DOJ findings report on Georgia's prison system contained 82 recommendations. Value: 82 recommendations Date: 2024-10-01 Tags: DOJ, recommendations, Georgia, GDC, reform Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 LEGAL FACTS (15) ---------------------------------------- - [confirmed] UN Mandela Rules 15-day maximum for solitary confinement The UN Mandela Rules define prolonged solitary confinement as exceeding 15 consecutive days and classify it as a form of torture. Date: 2015-12-17 Tags: Mandela Rules, UN, international standards, torture, solitary confinement Sources: UN General Assembly Resolution 70/175 - [confirmed] Mandela Rules adopted December 17, 2015 The United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) were adopted by the UN General Assembly on December 17, 2015, through Resolution 70/175. Date: 2015-12-17 Tags: Mandela Rules, UN, international standards, Resolution 70/175 Sources: UN General Assembly Resolution 70/175 - [confirmed] Mandela Rules definition of solitary confinement Rule 44 of the Mandela Rules defines solitary confinement as 'the confinement of prisoners for 22 hours or more a day without meaningful human contact.' Date: 2015-12-17 Tags: Mandela Rules, definition, solitary confinement, Rule 44 Sources: UN General Assembly Resolution 70/175 - [confirmed] Mandela Rules prohibit indefinite solitary confinement Rules 43 and 45 of the Mandela Rules establish that indefinite solitary confinement is prohibited under all circumstances. Date: 2015-12-17 Tags: Mandela Rules, indefinite solitary, prohibition, Rules 43 45 Sources: UN General Assembly Resolution 70/175 - [confirmed] Mandela Rules: solitary only as last resort with independent review The Mandela Rules specify that solitary confinement 'shall be used only in exceptional cases as a last resort, for as short a time as possible and subject to independent review.' Date: 2015-12-17 Tags: Mandela Rules, last resort, independent review, exceptional cases Sources: UN General Assembly Resolution 70/175 - [confirmed] UN Special Rapporteur Méndez: solitary over 15 days is torture (2011) In 2011, UN Special Rapporteur on Torture Juan E. Méndez declared that solitary confinement exceeding 15 days constitutes torture. Date: 2011-08-01 Tags: UN, torture, Juan Méndez, Special Rapporteur, 15 days Sources: UN Special Rapporteur on Torture, Interim Report, August 2011 (A/66/268) - [confirmed] First Step Act banned juvenile solitary in federal system (2018) The First Step Act (2018) codified a ban on juvenile solitary confinement in the federal system. This remains the only enacted federal legislation directly addressing solitary confinement. Date: 2018-01-01 Tags: First Step Act, federal legislation, juvenile, solitary confinement, enacted - [confirmed] Eleventh Circuit has no definitive ruling on solitary and Eighth Amendment The Eleventh Circuit, which governs Georgia, Alabama, and Florida, has not issued a definitive ruling on the constitutional limits of solitary confinement under the Eighth Amendment. Tags: Eleventh Circuit, Georgia, Eighth Amendment, constitutional law, circuit split, solitary confinement Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Third Circuit: 33 years of solitary can be cruel and unusual (Porter v. PA DOC) In Porter v. Pennsylvania DOC (974 F.3d), the Third Circuit found that 33 years of solitary confinement can demonstrate cruel and unusual punishment. Date: 2020-01-01 Tags: Third Circuit, Porter v. PA DOC, cruel and unusual punishment, Eighth Amendment Sources: Porter v. Pennsylvania DOC, 974 F.3d (2020) - [confirmed] In re Medley (1890): Supreme Court recognized solitary's severe effects In In re Medley (1890), the Supreme Court recognized solitary confinement's severe psychological effects, noting prisoners fell into a 'semi-fatuous condition,' became 'violently insane,' or committed suicide. This 135-year-old case remains the most significant Supreme Court statement on solitary confinement. Date: 1890-01-01 Tags: Supreme Court, In re Medley, 1890, solitary confinement, historical, constitutional law Sources: In re Medley, 134 U.S. 160 (1890) - [confirmed] January 2019 settlement agreement: sweeping SMU reforms required The January 2019 settlement agreement in Gumm v. Jacobs required: minimum 3 hours out-of-cell time in common areas (in restraints) plus 1 hour outdoor recreation; within 6 months, 2 hours per week of computer time or educational classes and GED programs; prison-issued tablets in cells at all times; access to programming, mental health evaluations, and books; food servings consistent with general population standards; maximum 24 months in SMU except in narrowly defined circumstances; and committee review for transfer 6–12 months before release. Date: 2019-01-01 Tags: Gumm v. Jacobs, settlement agreement, SMU reforms, out-of-cell time, programming, 24-month maximum Sources: Gumm v. Jacobs litigation filings - [confirmed] Court appointed independent monitor at GDC expense The April 2024 contempt order imposed several penalties including appointment of an independent monitor at GDC's expense. Date: 2024-04-01 Tags: independent monitor, contempt, GDC, court oversight, Gumm v. Jacobs Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Court extended settlement agreement and ordered attorney's fees The April 2024 contempt order also extended the settlement agreement, ordered attorney's fees for enforcement costs, and threatened additional sanctions. Date: 2024-04-01 Tags: settlement extension, attorney fees, sanctions, contempt, GDC, Gumm v. Jacobs Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Madrid v. Gomez (1995): risk of harm for vulnerable inmates in Pelican Bay SHU In the landmark case Madrid v. Gomez (1995), concerning California's Pelican Bay SHU, the Ninth Circuit recognized a substantial risk of harm from solitary confinement for mentally ill or otherwise vulnerable inmates, though it did not find a categorical prohibition. Date: 1995-01-01 Tags: Madrid v. Gomez, Pelican Bay, Ninth Circuit, vulnerable inmates, mental illness - [confirmed] Harden-Bey v. Rutter: Sixth Circuit dismissed after 3+ years solitary In Harden-Bey v. Rutter, the Sixth Circuit dismissed a solitary confinement claim after more than 3 years of solitary, requiring a showing of 'extreme deprivations.' Tags: Sixth Circuit, Harden-Bey v. Rutter, extreme deprivations, dismissed FINDINGS (16) ---------------------------------------- - [confirmed] Academic research consistency on solitary confinement harm spans 150+ years A comprehensive review published in Crime and Justice in 2018 found that research on psychological harm from solitary confinement has been 'strikingly consistent since the early nineteenth century,' spanning different methodologies, populations, and time periods. Date: 2018-01-01 Tags: academic research, solitary confinement, psychological harm, literature review Sources: The Psychological Effects of Solitary Confinement: A Systematic Critique - [confirmed] Grassian's identification of solitary confinement psychiatric syndrome Dr. Stuart Grassian of Harvard Medical School described solitary confinement conditions as 'strikingly toxic to mental functioning, producing a stuporous condition associated with perceptual and cognitive impairment and affective disturbances.' He identified a specific psychiatric syndrome including hypersensitivity to external stimuli, perceptual distortions and hallucinations, panic attacks, difficulty thinking and concentrating, memory problems, paranoia, and impulse control issues. Date: 2006-01-01 Tags: Stuart Grassian, psychiatric syndrome, solitary confinement, psychological harm, Harvard Sources: Stuart Grassian, Psychiatric Effects of Solitary Confinement, Washington University Journal of Law & Policy, Vol. 22, 2006 - [confirmed] Grassian finding on florid delirium in severe cases In severe cases of solitary confinement, prisoners develop what Grassian termed 'florid delirium—a confusional psychosis with intense agitation, fearfulness, and disorganization.' Date: 2006-01-01 Tags: Stuart Grassian, psychiatric syndrome, psychosis, delirium, solitary confinement Sources: Stuart Grassian, Psychiatric Effects of Solitary Confinement, Washington University Journal of Law & Policy, Vol. 22, 2006 - [confirmed] Grassian finding on harm to psychologically resilient inmates Dr. Stuart Grassian found that even psychologically resilient inmates suffer 'severe psychological pain' from prolonged isolation, and that the harm may result in 'prolonged or permanent psychiatric disability.' Date: 2006-01-01 Tags: Stuart Grassian, permanent disability, solitary confinement, psychological harm Sources: Stuart Grassian, Psychiatric Effects of Solitary Confinement, Washington University Journal of Law & Policy, Vol. 22, 2006 - [confirmed] 2025 PLOS One meta-analysis sample size of 171,300 inmates A landmark meta-analysis published in PLOS One in June 2025 synthesized data from 171,300 inmates across multiple studies and found significantly greater psychological distress, more psychiatric symptoms (including self-harm, thought disorders, and obsessive-compulsive symptoms), and greater need for mental health services and hospitalizations among prisoners in disciplinary confinement compared to the general prison population. Date: 2025-06-01 Tags: meta-analysis, PLOS One, solitary confinement, psychological distress, self-harm, mental health Sources: Meta-analysis on psychological effects of solitary confinement, PLOS One, June 2025 - [confirmed] Premature deaths more likely for those with solitary history after release Research has demonstrated that premature deaths—including suicide, homicide, and opioid overdose—after release from prison are significantly more likely for individuals who spent any time in solitary confinement during their incarceration, compared to those who were never placed in isolation. Date: 2018-01-01 Tags: premature death, suicide, homicide, opioid overdose, post-release, solitary confinement Sources: Hagan et al., History of Solitary Confinement Is Associated with Post-Traumatic Stress Disorder Symptoms among Individuals Recently Released from Prison, Journal of Urban Health, 2018 - [confirmed] Observation cell paradox: suicide watch cells filled from segregation Suicide watch cells are disproportionately filled with prisoners transferred from segregation units, indicating a pattern of cycling between isolation and crisis intervention rather than adequate mental health care. Tags: suicide watch, segregation, cycling, mental health care, observation cell Sources: The Psychological Effects of Solitary Confinement: A Systematic Critique - [confirmed] Augustine and Pifer cycling study: three reentry shocks identified A 2025 study by Dr. Dallas Augustine and Dr. Natalie Pifer found that prisoners transitioning from long-term solitary to general population experience three core 'reentry shocks': (1) sensory overload, (2) social disorientation, and (3) institutional whiplash. Date: 2025-01-01 Tags: cycling, reentry shocks, sensory overload, social disorientation, institutional whiplash, solitary confinement Sources: Augustine & Pifer, Unexceptional Patterns of Solitary Confinement: Cycling and Reentry Shocks Within the Prison, 2025 - [confirmed] Some prisoners deliberately return to solitary due to familiarity The 2025 Augustine and Pifer study found that some individuals deliberately commit infractions to return to solitary where conditions, while harmful, are at least familiar and predictable. Date: 2025-01-01 Tags: cycling, deliberate infractions, familiarity, institutional incentives, solitary confinement Sources: Augustine & Pifer, Unexceptional Patterns of Solitary Confinement: Cycling and Reentry Shocks Within the Prison, 2025 - [confirmed] Gang labeling amplifies solitary placement risk and duration A 2025 study by Tublitz and colleagues found that gang labeling 'sticks' even after formal debriefing, amplifying risks for solitary placement and extending the duration of isolation for affected individuals. Date: 2025-01-01 Tags: gang labeling, racial disparity, solitary confinement, duration, debriefing Sources: Tublitz et al., 2025 - [confirmed] GDC compliance documents found falsified The April 2024 contempt order found that GDC compliance documents were 'not only insufficient but also unreliable'—officials falsified documentation. Date: 2024-04-01 Tags: GDC, falsified documents, compliance, contempt, fraud, accountability Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Housing in shower stalls dramatically increases suicide risk per corrections industry The corrections industry has long documented that housing individuals in shower stalls dramatically increases suicide risk. Tags: shower stall housing, suicide risk, corrections industry, best practices Sources: Gumm v. Jacobs litigation filings - [confirmed] DOJ found queer/transgender prisoners placed in solitary after reporting assault The DOJ 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. Date: 2024-10-01 Tags: DOJ, LGBTQ, transgender, sexual assault, solitary confinement, punitive isolation, Georgia Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] Vulnerable prisoners forced to sleep in hallways, shower stalls, or outside The DOJ found that vulnerable prisoners were forced to sleep in hallways, shower stalls, or outside after other prisoners used threats of violence to take their assigned beds. Date: 2024-10-01 Tags: DOJ, vulnerable prisoners, hallways, shower stalls, housing management, Georgia Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] Low staffing made outdoor exercise impossible at SMU Extremely low staffing levels at Georgia's SMU made outdoor exercise impossible except when tactical officers were temporarily present. Date: 2024-04-01 Tags: staffing, outdoor exercise, SMU, Georgia, contempt, GDC Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Washington State 2024 study: three qualitative themes The 2024 Washington State study's qualitative analysis revealed three dominant themes among long-term solitary confinement prisoners: social isolation, loss of identity, and sensory hypersensitivity. Date: 2024-01-01 Tags: Washington State, qualitative, social isolation, loss of identity, sensory hypersensitivity Sources: Washington State 2024 study on long-term solitary confinement QUOTES (10) ---------------------------------------- - [confirmed] UN Special Rapporteur Melzer: prolonged solitary is psychological torture (2020) In 2020, UN Special Rapporteur on Torture Nils Melzer stated that 'prolonged solitary confinement amounts to psychological torture.' Date: 2020-01-01 Tags: UN, torture, Nils Melzer, Special Rapporteur, psychological torture - [confirmed] Fourth Circuit cited research showing negative effects after 10+ days The Fourth Circuit cited research showing that 'not a single study of solitary confinement lasting more than 10 days failed to result in negative psychological effects.' Tags: Fourth Circuit, research evidence, 10 days, psychological effects - [confirmed] Fifth Circuit: solitary does not violate Eighth Amendment regardless of duration In Hope v. Harris (2021), the Fifth Circuit held that solitary confinement does not violate the Eighth Amendment 'no matter how long it is imposed for, its impact on prisoner's mental and physical health, or rationale for imposing it.' Date: 2021-01-01 Tags: Fifth Circuit, Hope v. Harris, Eighth Amendment, absolutist position - [confirmed] Dr. Craig Haney described Georgia SMU as 'one of the harshest and most draconian' Dr. Craig Haney described Georgia's Special Management Unit as 'one of the harshest and most draconian' solitary confinement facilities in the nation and 'as chaotic and out-of-control as any such unit I have seen in decades of conducting evaluations.' Date: 2017-01-01 Tags: Craig Haney, Georgia, SMU, expert assessment, harshest, draconian Sources: Gumm v. Jacobs litigation filings - [confirmed] Haney warned of 'irreversible and even fatal harm' at SMU Dr. Craig Haney concluded that conditions in Georgia's SMU create a 'significant risk of very serious psychological harm,' particularly given the high number of prisoners with mental illness, and warned of the risk of 'irreversible and even fatal harm.' Date: 2017-01-01 Tags: Craig Haney, Georgia, SMU, psychological harm, irreversible, fatal Sources: Gumm v. Jacobs litigation filings - [confirmed] Judge Treadwell quote: GDC running 'four-corner offense' with no intention to comply Chief Judge Marc T. Treadwell stated: 'It became clear to the Court that the defendants, in effect, were running a four-corner offense and had no desire or intention to comply with the Court's injunction; they would stall until the injunction expired.' Date: 2024-04-01 Tags: Judge Treadwell, contempt, GDC, noncompliance, Gumm v. Jacobs, quote Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] DOJ: victims bled out from treatable stab wounds waiting for guard escorts The DOJ noted that victims of gang violence have 'bled out from treatable stab wounds, waiting for a guard escort,' illustrating how staffing shortages intersect with isolation practices to create compounding risks of harm. Date: 2024-10-01 Tags: DOJ, staffing shortages, treatable injuries, death, guard escort, Georgia Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] AAG Kristen Clarke statement on Georgia prison conditions Assistant Attorney General for Civil Rights Kristen Clarke stated: 'Our findings report lays bare the horrific and inhumane conditions that people are confined to inside Georgia's state prison system. People are assaulted, stabbed, raped and killed or left to languish inside facilities that are woefully understaffed. Inmates are maimed and tortured, relegated to an existence of fear, filth and not so benign neglect.' Date: 2024-10-01 Tags: Kristen Clarke, DOJ, Civil Rights Division, Georgia, inhumane conditions, quote Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] GDC disputed DOJ findings GDC disputed the DOJ findings, claiming that the DOJ 'fundamentally misunderstands current challenges of operating any prison system' and noting that similar issues plague the Federal Bureau of Prisons. Date: 2024-10-01 Tags: GDC, DOJ, disputed findings, response, defense Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] Nelson Mandela spent 27 years in prison Nelson Mandela, for whom the Mandela Rules are named, spent 27 years in prison and called solitary confinement 'the most forbidding aspect of prison life.' Tags: Nelson Mandela, Mandela Rules, quote, solitary confinement Sources: UN General Assembly Resolution 70/175 POLICYS (12) ---------------------------------------- - [confirmed] New York HALT Act limits solitary to 15 consecutive days New York's HALT Solitary Confinement Act (signed April 2021, effective April 2022) limits solitary confinement to a maximum of 15 consecutive days and defines solitary as 17 or more hours per day in a cell. Date: 2021-04-01 Tags: New York, HALT Act, legislative reform, 15 days, solitary confinement Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] HALT Act prohibits solitary for specific vulnerable populations The New York HALT Act prohibits solitary confinement for those 21 years old or younger, those 55 or older, pregnant or postpartum individuals, those with disabilities, and those with serious mental illness. Date: 2021-04-01 Tags: New York, HALT Act, vulnerable populations, youth, elderly, pregnant, mental illness, disabilities Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] HALT Act requires minimum 4 hours out-of-cell programming daily The New York HALT Act requires a minimum of 4 hours of out-of-cell programming daily and mandates evidentiary hearings for all solitary confinement placements. Date: 2021-04-01 Tags: New York, HALT Act, out-of-cell programming, evidentiary hearings Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] Connecticut and Nevada enacted 15-day maximum limits (June 2023) Connecticut and Nevada enacted 15-day maximum limits on solitary confinement, aligning with the Mandela Rules, as of June 2023. Date: 2023-06-01 Tags: Connecticut, Nevada, 15-day limit, Mandela Rules, legislative reform Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] New Jersey 20-day maximum under Isolated Confinement Restriction Act (2020) New Jersey's Isolated Confinement Restriction Act (2020) established a 20 consecutive day maximum for solitary confinement. Date: 2020-01-01 Tags: New Jersey, Isolated Confinement Restriction Act, 20-day limit, legislative reform Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Four states eliminated restrictive housing entirely (2019–2020) Colorado, Delaware, North Dakota, and Vermont no longer house individuals under restrictive housing definitions as of 2019–2020 reports. Date: 2020-01-01 Tags: Colorado, Delaware, North Dakota, Vermont, elimination, restrictive housing Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] End Solitary Confinement Act: 4-hour maximum federal isolation The End Solitary Confinement Act (introduced 2023, reintroduced 2025) would prohibit isolation except for a maximum of 4 hours in federal facilities. Date: 2025-01-01 Tags: federal legislation, End Solitary Confinement Act, 4-hour maximum, introduced not enacted - [confirmed] Virginia passed comprehensive solitary legislation in 2023 Virginia passed comprehensive solitary confinement reform legislation in 2023. Date: 2023-01-01 Tags: Virginia, legislative reform, solitary confinement, comprehensive Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Massachusetts comprehensive restrictive housing statute Massachusetts enacted a comprehensive statute defining restrictive housing as more than 22 hours per day in a cell, requiring mental health screening, prohibiting placement for vulnerable populations, and mandating regular reviews. Tags: Massachusetts, restrictive housing, mental health screening, vulnerable populations, legislative reform Sources: Liman Center/CLA Census data, Yale Law School - [reported] 2026 Georgia gubernatorial race as advocacy window The 2026 Georgia gubernatorial race is identified as a critical advocacy window for pressing candidates on solitary confinement reform commitments. Date: 2026-01-01 Tags: Georgia, gubernatorial race, 2026, advocacy, solitary confinement reform Sources: GPS Research Brief, February 2026 - [confirmed] Common state reform provisions Common provisions in state solitary confinement reforms include annual reporting requirements, demographic data collection mandates, limits on maximum duration, protections for vulnerable populations (those with mental illness, pregnant women, youth, elderly), and requirements for mental health screening before and during placement. Tags: legislative reform, common provisions, reporting, duration limits, vulnerable populations, mental health screening Sources: Liman Center/CLA Census data, Yale Law School - [confirmed] Solitary Confinement Reform Act (2024) introduced but not enacted The Solitary Confinement Reform Act (2024) would prohibit solitary for specific subpopulations and require 4 hours of out-of-cell time daily for all federal prisoners. It was introduced but not enacted. Date: 2024-01-01 Tags: federal legislation, Solitary Confinement Reform Act, introduced not enacted CASE DETAILS (21) ---------------------------------------- - [reported] New York correctional officers' strike March 2025 In March 2025, a correctional officers' strike in New York led to temporary suspension of HALT Act programming elements. Date: 2025-03-01 Tags: New York, HALT Act, correctional officers, strike, programming suspension Sources: New York HALT Solitary Confinement Act, S.2836/A.2500 - [confirmed] Supreme Court denied cert in Hope v. Harris (27 years of solitary) In 2023, the Supreme Court denied certiorari in Hope v. Harris, involving Dennis Wayne Hope who had been held in continuous solitary confinement for 27 years (1994–2021), confined 22–24 hours per day in a 54-square-foot cell, receiving only one personal phone call since 1994. Date: 2023-01-01 Tags: Supreme Court, cert denied, Hope v. Harris, Dennis Wayne Hope, 27 years, circuit split Sources: Hope v. Harris, cert. denied 2023 - [confirmed] SMU cell dimensions approximately 6 feet by 9 feet Cells in Georgia's Special Management Unit measured approximately 6 feet by 9 feet—roughly the size of a parking space—with solid metal doors having only a small glass window. Tags: Georgia, SMU, cell size, physical conditions, solitary confinement Sources: Gumm v. Jacobs litigation filings - [confirmed] SMU most restrictive cellblocks: 22–24 hours per day confined In the most restrictive cellblocks of the SMU, prisoners were confined for 22 to 24 hours per day alone, without books or personal property, and were prohibited from leaving their cells for a minimum of 90 days upon arrival. Tags: Georgia, SMU, hours confined, no property, 90-day lockdown, physical conditions Sources: Gumm v. Jacobs litigation filings - [confirmed] SMU cells had no outside light due to exterior window shield Cells in the SMU had no outside light—a small exterior window was covered by a shield. Tags: Georgia, SMU, physical conditions, no natural light, sensory deprivation Sources: Gumm v. Jacobs litigation filings - [confirmed] SMU characterized by constant din, feces stench, dampness, mildew The SMU facility was characterized by a constant din of yelling and banging, a permeating stench of feces, and dampness and mildew from in-cell showers. Meals were passed through a slot in the door. Tags: Georgia, SMU, physical conditions, sanitation, noise, mildew Sources: Gumm v. Jacobs litigation filings - [confirmed] Timothy Gumm held in SMU for 7.5 years Timothy Gumm was held in Georgia's SMU for 7.5 years. There had been 14 separate recommendations over 4 years that he be transferred out of the SMU, yet he remained. Tags: Timothy Gumm, Georgia, SMU, long-term isolation, transfer recommendations, institutional indifference Sources: Gumm v. Jacobs litigation filings - [confirmed] Johnny Mack Brown held in SMU for 9 years Johnny Mack Brown was held in Georgia's Special Management Unit for 9 years. Tags: Johnny Mack Brown, Georgia, SMU, long-term isolation Sources: Gumm v. Jacobs litigation filings - [confirmed] Robert Watkins held in SMU for 8–10 years Robert Watkins was held in Georgia's Special Management Unit for 8 to 10 years. Tags: Robert Watkins, Georgia, SMU, long-term isolation Sources: Gumm v. Jacobs litigation filings - [confirmed] Gumm v. Jacobs lawsuit filed 2015 as pro se complaint In 2015, Timothy Gumm, serving a life sentence for rape, filed a handwritten pro se lawsuit challenging SMU conditions after 5 years in isolation. He had been placed in the SMU following a failed escape attempt in 2010. Date: 2015-01-01 Tags: Gumm v. Jacobs, Timothy Gumm, pro se, lawsuit filed, SMU, escape attempt Sources: Gumm v. Jacobs litigation filings - [confirmed] 2018: SCHR and Kilpatrick Townsend filed class action motion In 2018, the Southern Center for Human Rights (SCHR) and the law firm Kilpatrick Townsend & Stockton LLP filed a motion for preliminary injunction on behalf of a class of prisoners in the SMU. Date: 2018-01-01 Tags: Gumm v. Jacobs, SCHR, Kilpatrick Townsend, class action, preliminary injunction Sources: Gumm v. Jacobs litigation filings - [confirmed] GDC placed people in strip cells upon SMU arrival The April 2024 contempt order documented that GDC officials placed people in 'strip cells' upon arrival at the SMU, taking their clothing and leaving them naked or near-naked for hours or days. Date: 2024-04-01 Tags: GDC, strip cells, nakedness, SMU, contempt, inhumane conditions Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Prisoner testimony: broken toilet, no mattress, no clothing, freezing temperatures In the contempt proceedings, one prisoner described a cell where the toilet was broken and filled with feces and urine from prior occupants. He was forced to urinate in a cup and pour it in the sink, or defecate on toilet paper and dispose of it on his food tray. He had no mattress, no clothing, and was held in freezing temperatures. The GDC attorney did not refute this testimony. Date: 2024-04-01 Tags: GDC, SMU, prisoner testimony, broken toilet, no mattress, freezing, inhumane conditions, contempt Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Six prisoners testified about conditions in contempt proceedings Six prisoners testified in the contempt proceedings about being denied showers, out-of-cell time, programming, cell cleanout, and access to kiosks and book carts. Date: 2024-04-01 Tags: prisoner testimony, contempt, GDC, SMU, denial of services Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Smith State Prison: inmate held in shower stall for nearly 3 days, hanged himself At Smith State Prison in Glennville, an inmate was held in a shower stall measuring 3.75 feet by 6.75 feet for nearly 3 days. The stall had no mattress, no toilet, no ventilation, no heat, and no water. The inmate ultimately hanged himself. Tags: Smith State Prison, Glennville, shower stall, suicide, hanging, inhumane conditions Sources: Gumm v. Jacobs litigation filings - [confirmed] DOJ civil investigation of Georgia prisons launched September 2021 The U.S. Department of Justice launched a statewide civil investigation of Georgia's prison system in September 2021. Date: 2021-09-01 Tags: DOJ, investigation, Georgia, GDC, civil rights Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] DOJ findings report published October 1, 2024 The U.S. Department of Justice published its 93-page findings report on Georgia's prison system on October 1, 2024. Date: 2024-10-01 Tags: DOJ, findings report, Georgia, GDC, 93 pages Sources: Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024 - [confirmed] Contempt order was 100 pages long The April 2024 contempt order issued by Chief Judge Marc T. Treadwell was 100 pages long. Date: 2024-04-01 Tags: contempt order, 100 pages, Judge Treadwell, Gumm v. Jacobs Sources: Gumm v. Jacobs Contempt Order April 2024 - [confirmed] Dennis Wayne Hope: one personal phone call since 1994 Dennis Wayne Hope, held in continuous solitary confinement for 27 years (1994–2021), received only one personal phone call since 1994. Date: 2023-01-01 Tags: Dennis Wayne Hope, solitary confinement, phone call, Hope v. Harris Sources: Hope v. Harris, cert. denied 2023 - [confirmed] Dennis Wayne Hope's cell was 54 square feet Dennis Wayne Hope was confined 22–24 hours per day in a 54-square-foot cell during his 27 years of continuous solitary confinement. Tags: Dennis Wayne Hope, cell size, Hope v. Harris, solitary confinement Sources: Hope v. Harris, cert. denied 2023 - [confirmed] Gumm placed in SMU after failed escape attempt in 2010 Timothy Gumm was placed in the SMU following a failed escape attempt in 2010. He was serving a life sentence for rape. Date: 2010-01-01 Tags: Timothy Gumm, escape attempt, SMU placement, life sentence Sources: Gumm v. Jacobs litigation filings DATA GAPS (5) ---------------------------------------- - [reported] GPS recommended data gap: current SMU population data needed GPS identifies a data gap regarding current SMU population data including duration of confinement, mental health diagnoses, and demographic breakdown, recommending open records requests. Date: 2026-02-01 Tags: data gap, SMU, open records, population data, mental health, demographics Sources: GPS Research Brief, February 2026 - [reported] GPS recommended data gap: independent monitor reports since April 2024 GPS recommends requesting the independent monitor's reports filed since the April 2024 contempt order to assess whether SMU conditions have improved. Date: 2026-02-01 Tags: data gap, independent monitor, contempt order, compliance Sources: GPS Research Brief, February 2026 - [reported] GPS recommended data gap: current staffing levels at Georgia Diagnostic GPS recommends seeking current data on GDC staffing levels at Georgia Diagnostic and Classification Prison specifically. Date: 2026-02-01 Tags: data gap, staffing, Georgia Diagnostic, GDC Sources: GPS Research Brief, February 2026 - [reported] GPS recommended data gap: cross-reference mortality database with housing data GPS recommends cross-referencing its mortality database with any available housing assignment data to test the solitary-suicide correlation in Georgia specifically. Date: 2026-02-01 Tags: data gap, mortality, suicide, housing assignment, cross-reference, Georgia Sources: GPS Research Brief, February 2026 - [reported] GPS recommended: investigate DOJ enforcement action status GPS recommends investigating whether the DOJ has taken any enforcement action since the October 2024 findings report, or whether the case is heading toward a consent decree or litigation. Date: 2026-02-01 Tags: data gap, DOJ, enforcement, consent decree, Georgia Sources: GPS Research Brief, February 2026 DATASETS (6) ---------------------------------------- # Georgia SMU Duration of Isolation (July 2017) Duration of confinement for 182 prisoners held in Georgia's Special Management Unit as of July 2017 Duration Threshold Number of Prisoners Percentage ----------------------------------------------------- > 2 years 141 78 > 4 years 80 44 > 5 years 47 26 # U.S. Solitary Confinement Population Estimates (2014–2021) Estimated number of people held in solitary confinement or restrictive housing in the United States over time, from Liman Center/CLA Census data Year Estimated People in Solitary (Low) Estimated People in Solitary (High) Notes --------------------------------------------------------------------------------------------------------------------------------- 2014 80000 100000 Widely cited estimate 2016 68000 68000 First Liman census 2019 31542 31542 3.8% of 825,473 prisoners in 39 reporting states 2021 41000 48000 Estimated; pandemic may have increased use # Haney Symptom Prevalence in Solitary Confinement Percentage of prisoners in solitary confinement reporting specific psychological symptoms, from Dr. Craig Haney's research (2003) Symptom Percentage Reporting --------------------------------------------------- Anxiety 91 Oversensitivity to stimuli 86 Social withdrawal 83 Chronic depression 77 Impending nervous breakdown 70 Heart palpitations 68 # Federal Circuit Split on Solitary Confinement and Eighth Amendment Summary of federal circuit court positions on whether solitary confinement can violate the Eighth Amendment Circuit Key Case Position Georgia Impact ---------------------------------------------------------------------------------------------------------------------------------------- Third Porter v. PA DOC (2020); Williams (2024) CAN violate 8th Amend. Not binding; persuasive authority Fourth Cited extensive research CAN violate 8th Amend. Not binding; persuasive Fifth Hope v. Harris (2021) Does NOT violate 8th Am. Not binding; adverse precedent Sixth Harden-Bey; Finley v. Huss (2024) Does NOT per se violate Not binding Ninth Madrid v. Gomez (1995) Risk of harm for vulnerable Not binding; persuasive Eleventh (Georgia's circuit) No definitive ruling No definitive ruling DIRECTLY GOVERNING # BOP Racial Disparities in SMU Placement (2022) Federal Bureau of Prisons racial composition of total population vs. Special Management Unit placements, 2022 Race Percent of Total BOP Population Percent of SMU Placements ------------------------------------------------------------------- Black 38 59 White 58 35 # Individual Extreme Duration Cases in Georgia SMU Named individuals held for extreme durations in Georgia's Special Management Unit Name Duration in SMU (Years) -------------------------------------------- Timothy Gumm 7.5 Johnny Mack Brown 9 Robert Watkins 8–10 KEY ENTITIES (46) ---------------------------------------- - ACLU National Prison Project [organization]: Active in restrictive housing reform litigation and policy advocacy nationwide. (aka: ACLU) - Clark v. Coupe [case]: Third Circuit case (55 F.4th 167, 2022) reaffirming an exception for people with mental illness, finding that isolation of mentally ill prisoners presents distinct constitutional concerns. - Correctional Leaders Association [organization]: Partner organization with the Liman Center in conducting the national census of restrictive housing use. (aka: CLA) - Craig Haney [person]: Professor of psychology at the University of California, Santa Cruz. Leading national expert on psychological effects of solitary confinement. Conducted inspection of Georgia's SMU for Gumm v. Jacobs litigation and described it as 'one of the harshest and most draconian' in the nation. (aka: Dr. Craig Haney) - Dallas Augustine [person]: Washington State University researcher and co-author of the 2025 study on cycling and reentry shocks in solitary confinement. (aka: Dr. Dallas Augustine) - Dennis Wayne Hope [person]: Prisoner held in continuous solitary confinement for 27 years (1994–2021) in a 54-square-foot cell. Plaintiff in Hope v. Harris; Supreme Court denied certiorari in 2023. - DOJ Investigation of Georgia Department of Corrections [operation]: Statewide civil investigation launched September 2021 by the U.S. DOJ Civil Rights Division. Published 93-page findings report October 1, 2024, documenting pattern of unconstitutional conditions including violence, sexual abuse, systemic failures, and solitary confinement misuse. (aka: DOJ Georgia Investigation) - End Solitary Confinement Act [legislation]: Federal legislation introduced in 2023 and reintroduced in 2025 that would prohibit isolation except for a maximum of 4 hours in federal facilities. Not enacted. - Federal Bureau of Prisons [organization]: Federal agency operating the U.S. federal prison system. 2022 data showed racial disparities in SMU placements. GDC cited BOP's similar challenges in disputing DOJ findings. (aka: BOP) - Finley v. Huss [case]: Sixth Circuit case (102 F.4th 789, 2024) affirming summary judgment for defendants in a solitary confinement challenge. - First Step Act [legislation]: Federal legislation enacted in 2018 that codified a ban on juvenile solitary confinement in the federal system. The only enacted federal legislation directly addressing solitary confinement. - Georgia Department of Corrections [organization]: Georgia state agency responsible for operating the state prison system. Subject of DOJ investigation and federal court contempt order for conditions in solitary confinement. (aka: GDC) - Georgia Diagnostic and Classification Prison [facility]: State prison located in Jackson, Georgia, housing the Special Management Unit (SMU), the state's primary long-term solitary confinement facility. (aka: Georgia Diagnostic, GDCP) - Georgia Prisoners' Speak [organization]: Journalism organization documenting conditions in Georgia's prison system. Operating as The GDC Accountability Project, Inc. Prepared this research brief in February 2026. (aka: GPS) - Gumm v. Jacobs [case]: Federal class action lawsuit challenging conditions in Georgia's Special Management Unit. Filed pro se by Timothy Gumm in 2015. Settlement reached January 2019. 100-page contempt order issued April 2024 finding GDC 'flagrantly violated' the settlement. Filed in U.S. District Court, Middle District of Georgia. - HALT Solitary Confinement Act [legislation]: New York state law signed April 2021, effective April 2022. Limits solitary to 15 consecutive days, defines solitary as 17+ hours/day in cell, prohibits solitary for vulnerable populations, requires 4 hours out-of-cell programming daily. Implementation troubled with 40% noncompliance rate found in April 2024. (aka: HALT Act, Humane Alternatives to Long-Term Solitary Confinement Act, S.2836/A.2500) - Harden-Bey v. Rutter [case]: Sixth Circuit case dismissing a solitary confinement claim after more than 3 years of solitary, requiring a showing of 'extreme deprivations.' - Hope v. Harris [case]: Fifth Circuit case (2021) holding solitary does not violate the Eighth Amendment regardless of duration. Involved Dennis Wayne Hope held 27 years in solitary. Supreme Court denied certiorari in 2023. - In re Medley [case]: 1890 Supreme Court case (134 U.S. 160) recognizing solitary confinement's severe psychological effects. Remains the most significant Supreme Court statement on solitary confinement 135 years later. - Isolated Confinement Restriction Act [legislation]: New Jersey law enacted in 2020 establishing a 20 consecutive day maximum for solitary confinement. - Johnny Mack Brown [person]: Prisoner held in Georgia's SMU for 9 years, cited as an extreme duration case in Gumm v. Jacobs litigation. - Juan E. Méndez [person]: UN Special Rapporteur on Torture who declared in 2011 that solitary confinement exceeding 15 days constitutes torture. - Judith Resnik [person]: Yale Law School professor who leads the Liman Center for Public Interest Law. Primary academic authority on national trends in restrictive housing policy. (aka: Prof. Judith Resnik) - Kilpatrick Townsend & Stockton LLP [organization]: Law firm that co-filed the class action motion in Gumm v. Jacobs in 2018 alongside the Southern Center for Human Rights. (aka: Kilpatrick Townsend) - Kristen Clarke [person]: Assistant Attorney General for Civil Rights, U.S. Department of Justice. Described the DOJ Georgia findings as revealing 'horrific and inhumane conditions.' - Liman Center for Public Interest Law [organization]: Center at Yale Law School that maintains the only longitudinal national census of restrictive housing, in partnership with the Correctional Leaders Association. Publishes definitive research on solitary confinement trends. (aka: Liman Center, Arthur Liman Center for Public Interest Law) - Liman Center/CLA National Census of Restrictive Housing [program]: The only longitudinal nationwide database on solitary confinement use, maintained by the Liman Center at Yale Law School in partnership with the Correctional Leaders Association. (aka: Liman Census, Seeing Solitary) - Madrid v. Gomez [case]: Landmark 1995 Ninth Circuit case concerning California's Pelican Bay SHU that recognized a substantial risk of harm from solitary confinement for mentally ill or otherwise vulnerable inmates. - Marc T. Treadwell [person]: Chief Judge, U.S. District Court for the Middle District of Georgia. Issued the 100-page contempt order in Gumm v. Jacobs (April 2024) finding GDC 'flagrantly violated' the settlement agreement. (aka: Chief Judge Treadwell) - Natalie Pifer [person]: Washington State University researcher and co-author of the 2025 study on cycling and reentry shocks in solitary confinement. (aka: Dr. Natalie Pifer) - Nelson Mandela [person]: Former South African president who spent 27 years in prison and called solitary confinement 'the most forbidding aspect of prison life.' The UN Mandela Rules are named for him. - Nelson Mandela Rules [legislation]: United Nations standards adopted December 17, 2015 (Resolution 70/175) establishing international consensus on humane treatment of prisoners, including the 15-day maximum for solitary confinement and definition of solitary as 22+ hours per day without meaningful human contact. (aka: UN Standard Minimum Rules for the Treatment of Prisoners, Mandela Rules) - Nils Melzer [person]: UN Special Rapporteur on Torture who stated in 2020 that 'prolonged solitary confinement amounts to psychological torture.' - Porter v. Pennsylvania DOC [case]: Third Circuit case (974 F.3d, 2020) finding that 33 years of solitary confinement can demonstrate cruel and unusual punishment. (aka: Porter v. PA DOC) - Prison Policy Initiative [organization]: Organization conducting research and policy analysis on mass incarceration, including solitary confinement data analysis. - Robert Watkins [person]: Prisoner held in Georgia's SMU for 8 to 10 years, cited as an extreme duration case in Gumm v. Jacobs litigation. - Smith State Prison [facility]: Georgia state prison located in Glennville, where an inmate was held in a shower stall for nearly 3 days before hanging himself. - Solitary Confinement Reform Act [legislation]: Federal legislation introduced in 2024 that would prohibit solitary for specific subpopulations and require 4 hours of out-of-cell time daily for all federal prisoners. Not enacted. - Solitary Watch [organization]: National organization dedicated to monitoring and advocacy around solitary confinement. Maintains news coverage and research databases. - Southern Center for Human Rights [organization]: Lead counsel in Gumm v. Jacobs. Primary Georgia-focused legal advocacy organization on prison conditions. Has called for DOJ intervention and monitors GDC conditions. (aka: SCHR) - Special Management Unit [facility]: Georgia's primary long-term solitary confinement unit, located at Georgia Diagnostic and Classification Prison in Jackson. Subject of Gumm v. Jacobs litigation and described by experts as 'one of the harshest and most draconian' in the nation. (aka: SMU) - Stuart Grassian [person]: Deceased Harvard Medical School psychiatrist whose clinical descriptions of the solitary confinement psychiatric syndrome remain foundational. Identified specific syndrome including hallucinations, panic attacks, paranoia, and in severe cases 'florid delirium.' (aka: Dr. Stuart Grassian) - The GDC Accountability Project, Inc. [organization]: Corporate entity under which Georgia Prisoners' Speak (GPS) operates. - Timothy Gumm [person]: Prisoner serving a life sentence for rape who filed the pro se lawsuit (Gumm v. Jacobs) challenging SMU conditions in 2015 after 5 years in isolation. Held in SMU for 7.5 years despite 14 transfer recommendations. Placed in SMU following a failed escape attempt in 2010. - U.S. Department of Justice Civil Rights Division [organization]: Federal agency that launched a statewide civil investigation of Georgia's prison system in September 2021 and published a 93-page findings report on October 1, 2024, documenting a pattern of unconstitutional conditions. (aka: DOJ, DOJ Civil Rights Division) - Williams v. Secretary Pennsylvania Department of Corrections [case]: Third Circuit case (117 F.4th 503, 2024) further developing the framework for solitary confinement as Eighth Amendment violation. (aka: Williams v. Sec'y PA DOC) SOURCES (21) ---------------------------------------- - Augustine & Pifer, Unexceptional Patterns of Solitary Confinement: Cycling and Reentry Shocks Within the Prison, 2025 by Dallas Augustine, Natalie Pifer (2025-01-01) [academic, primary] URL: https://doi.org/10.1177/00111287251320685 - Craig Haney, Mental Health Issues in Long-Term Solitary and Supermax Confinement, Crime & Delinquency, Vol. 49, No. 1, 2003, Crime & Delinquency by Craig Haney (2003-01-01) [academic, primary] URL: https://doi.org/10.1177/0011128702239239 - Federal Bureau of Prisons SMU placement data, 2022, Federal Bureau of Prisons (2022-01-01) [official_report, primary] - GPS Research Brief, February 2026, Georgia Prisoners' Speak / The GDC Accountability Project, Inc. by GPS Research Assistant (2026-02-01) [gps_original, secondary] - Gumm v. Jacobs Contempt Order April 2024, U.S. District Court, Middle District of Georgia by Chief Judge Marc T. Treadwell (2024-04-01) [legal_document, primary] - Gumm v. Jacobs litigation filings, U.S. District Court, Middle District of Georgia [legal_document, primary] - Hagan et al., History of Solitary Confinement Is Associated with Post-Traumatic Stress Disorder Symptoms among Individuals Recently Released from Prison, Journal of Urban Health, 2018, Journal of Urban Health by Hagan et al. (2018-01-01) [academic, primary] URL: https://doi.org/10.1007/s11524-017-0138-1 - Hope v. Harris, cert. denied 2023, U.S. Supreme Court / Fifth Circuit (2023-01-01) [legal_document, primary] - In re Medley, 134 U.S. 160 (1890), U.S. Supreme Court (1890-01-01) [legal_document, primary] URL: https://supreme.justia.com/cases/federal/us/134/160/ - Investigation of the Georgia Department of Corrections, U.S. DOJ, October 2024, U.S. Department of Justice, Civil Rights Division (2024-10-01) [official_report, primary] URL: https://www.justice.gov/d9/2024-09/findings_report_-_investigation_of_georgia_prisons.pdf - Liman Center Census, Yale Law School, Arthur Liman Center for Public Interest Law, Yale Law School [academic, primary] URL: https://law.yale.edu/arthur-liman-center-public-interest-law - Liman Center/CLA Census data, Yale Law School, Arthur Liman Center for Public Interest Law, Yale Law School by Judith Resnik et al. [data_portal, primary] URL: https://seeingsolitary.limancenter.yale.edu/ - Meta-analysis on psychological effects of solitary confinement, PLOS One, June 2025, PLOS One (2025-06-01) [academic, primary] URL: https://journals.plos.org/plosone/ - New York HALT Solitary Confinement Act, S.2836/A.2500, New York State Senate (2021-04-01) [legislation, primary] URL: https://www.nysenate.gov/legislation/bills/2021/S2836 - Porter v. Pennsylvania DOC, 974 F.3d (2020), Third Circuit Court of Appeals (2020-01-01) [legal_document, primary] - Stuart Grassian, Psychiatric Effects of Solitary Confinement, Washington University Journal of Law & Policy, Vol. 22, 2006, Washington University Journal of Law & Policy by Stuart Grassian (2006-01-01) [academic, primary] URL: https://openscholarship.wustl.edu/law_journal_law_policy/vol22/iss1/24/ - The Psychological Effects of Solitary Confinement: A Systematic Critique, Crime and Justice (2018-01-01) [academic, primary] URL: https://doi.org/10.1086/700824 - Tublitz et al., 2025 by Tublitz et al. (2025-01-01) [academic, primary] - UN General Assembly Resolution 70/175, United Nations General Assembly (2015-12-17) [legislation, primary] URL: https://www.unodc.org/documents/justice-and-prison-reform/Nelson_Mandela_Rules-E-ebook.pdf - UN Special Rapporteur on Torture, Interim Report, August 2011 (A/66/268), United Nations by Juan E. Méndez (2011-08-01) [official_report, primary] URL: https://www.ohchr.org/en/special-procedures/sr-torture - Washington State 2024 study on long-term solitary confinement (2024-01-01) [academic, primary]