Knowledge (XXG)

Solitary confinement in the United States

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387:, found that "every federal court that has considered claims by severely mentally ill prisoners held in solitary confinement has found this treatment unconstitutional". These court rulings are significant in light of the fact that more than half of the prisoners currently serving jail time in the US are mentally ill according to the US Bureau of Prisons. Furthermore, approximately 30% or more of prisoners in solitary confinement are mentally ill. These rulings have the potential to dramatically change how prisons deal with mentally ill inmates, as prison officials would no longer be able to "warehouse" "difficult" prisoners if they have a preexisting mental illness. These rulings do not guarantee that the mentally ill will not be put in solitary confinement; although they are considered a vulnerable group, these prisoners still have "limited" recourse to the Eighth Amendment. 257:, the Supreme Court set two requirements that must be fulfilled in order to challenge solitary confinement as "cruel and unusual". First, prisoners must show that a "substantial risk of serious harm to inmates" exists and second, that the prison officials were "deliberately indifferent" to such risk. To prove a prison official's "deliberate indifference," the prisoner must "show evidence that the official was 'actually' aware of a prisoner's serious need and chose to ignore it". Since the psychological impact of solitary confinement is not believed to be "objectively" cruel and unusual within the U.S. legal system, and because it is difficult to establish that prison officials are "indifferent" to prisoner health and safety, inmates and attorneys alleging these two requirements have faced limited success. 20: 85:. Prison officials argue that solitary confinement is a necessary method of separating violent prisoners from the general population, separating vulnerable inmates (such as juveniles) from other inmates, and punishing prisoners who attempt to cause riots or try to escape. Critics argue that it is a cruel form of punishment which has been demonstrated to have long-lasting negative psychological effects on inmates (with some critics further contending that long-term solitary confinement is a form of torture) and is an unnecessary method of sequestering violent or vulnerable inmates, who can be safely separated through more humane means. Court cases arguing that solitary confinement violates the 318:, the Supreme Court held that, in addition to the due process right to meaningful review, prisoners also have a due process right to "a statement of the reasons why they were placed or retained at the supermax" so they can better understand how to behave in the future in order to be released from solitary confinement. Lobel argues that this "implies that the officials must provide something more than a general statement that the prisoner is very dangerous". According to Lobel this is not what usually happens at supermax facilities, so the inmates' due process rights are violated in this way as well. 639:
reduce environmental stimulation and causes a feeling of loss of control over all aspects of a prisoner's daily life. These environmental risks include but are not limited to hypersensitivity to stimuli, distortions and hallucinations, increased anxiety and nervousness, diminished impulse control, severe and chronic depression, appetite loss and weight loss, heart palpitations, talking to oneself, problems sleeping, nightmares, self-mutilation, difficulties with thinking, concentration, and memory, and lower levels of brain function.
405:, and often the conditions of protective custody are similar to those of solitary confinement. Juvenile justice experts, social scientists, and national correctional standards all agree that solitary confinement is an "ineffective therapeutic tool" that is detrimental to juveniles who are still in an "uncertain, unformed state of social identity". Given that they are developing mentally and physically, some experts have suggested that "they are severely and permanently damaged by such conditions to a greater extent than adults". 218:. In contrast to the Supreme Court's inaction, lower courts have imposed constitutional limitations on the use of solitary confinement. Despite such limitations, the federal courts have refused to find that solitary confinement is per se unconstitutional. The U.S. has also effectively "insulated itself from any official sanction for international violations by not submitting to the jurisdiction" of committees that enforce the International Covenant on Civil and Political Rights (ICCPR) or of the Committee Against Torture (CAT). 398:. The court ruled that the current conditions were not "per se violative of the Eighth Amendment" with respect to all inmates. However, in regard to SHU's isolation of the mentally ill and the conditions of their solitary confinement, the court found that the prison had violated the Eighth Amendment. Despite it being a landmark case, the rulings of the case have yet to set a trend among cases against other prison systems because SHU's conditions were known to be more extreme and harsh than other supermax prisons. 471:
the state and local levels. Numerous states have passed bills banning the use of solitary for vulnerable groups including children, people with disabilities, and pregnant people, while several others have limited the use of solitary for all people to no more than 15 or 20 consecutive days. In states where such laws are in effect, corrections agencies have continued to hold people in solitary for days or months beyond the legal limit, pointing to the need for ongoing monitoring and enforcement.
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reasons. Some of these reasons include separating violent prisoners from the general population, separating vulnerable inmates (such as juveniles) from others, and punishing those prisoners who attempt to cause riots or try to escape. Prisoners argue, however, that the nature of these kinds of offenses does not justify the use of solitary confinement; in their eyes "there is simply no strong security need for the total social isolation that exists at some supermax prisons".
625:, a 27-year-old transgender woman who died in solitary on Rikers following an epileptic seizure, sparked further calls for solitary reform. In June 2022, New York City councilmembers introduced Intro 549, which would ban solitary confinement for all people in New York City jails. Though the bill has received support from a supermajority of councilmembers, it has yet to be voted on by the City Council. 685:
solitary confinement with prisoners who had been in the general prison population." They found that "24.2 percent of the prisoners held in solitary confinement were reconvicted of a violent crime compared to 20.5 percent of prisoners held in population." And this behavior may be attributed to the mental illnesses prisoners may develop, as well as the dehumanizing treatment they are subject to.
55:) generally comes in one of two forms: "disciplinary segregation," in which inmates are temporarily placed in solitary confinement as punishment for rule-breaking; and "administrative segregation," in which prisoners deemed to be a risk to the safety of other inmates, prison staff, or to themselves are placed in solitary confinement for extended periods of time, often months or years. 518:, representing individuals housed in the Pelican Bay SHU. As a result of the litigation, the California Department of Corrections and Rehabilitation (CDCR) agreed to end indefinite solitary confinement in its facilities and implement due process for placements in SHU. Monitoring of the settlement agreement is ongoing, as CDCR has been found to have repeatedly violated the reforms. 503:
the SHU were not only the "worst of the worst" who had committed egregious acts of violence, but also individuals who had been validated as gang members, which could happen if they were caught possessing artwork or literature deemed radical, or if they were accused of gang affiliation by someone who had "debriefed" in order to return to the general prison population.
74:. The practice expanded significantly in the nineteenth century, when it was viewed as a humane alternative to prevailing methods of punishment like public floggings. However, by the early 1900s it had largely passed into disuse due to its high cost and the view that it was unethical. It would return as a common form of incarceration during the 507:
participants across 33 California prisons. Key to the success of the strikes was the organizers' decision to put aside racial hostilities that had been fostered within the SHU, as well as sustained partnerships between strike participants and outside advocates that drew national and international attention to the strikes.
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and Prisoners' Legal Services of New York have filed a class action lawsuit against the state for perpetuating these and other violations of HALT. The Correctional Association of New York, a prison oversight nonprofit, has released a report documenting additional "numerous departures" from the law in
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The Massachusetts Department of Corrections has attempted to circumvent the solitary confinement reforms codified in the CJRA, for example by creating Secure Adjustment Units where people are held in isolation for 21 instead of 22 hours a day. Because these units hold people in isolation for one hour
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Solitary confinement has been shown to disproportionately affect people of color. In particular, Black and Latino individuals are placed in solitary at rates far higher than their white counterparts. A 2019 Correctional Leaders Association/Yale Law School study found that Black women make up 21.5% of
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The UN has "expressly prohibit solitary confinement of juveniles and individuals with mental illness". The Convention on the Rights of Persons with Disabilities and Convention on the Rights of the Child have played major roles in establishing the UN's position on solitary confinement of mentally ill
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Recognizing that the amount of proof needed to show that solitary confinement violates prisoners' rights "is simply too high to trigger constitutional protections," attorneys have started to approach solitary confinement from a different angle. John F. Cockrell, a recent graduate from the University
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In 2021, New York's Humane Alternatives to Long-Term (HALT) Solitary Confinement Act was passed and signed into law after more than a decade of activism. The most progressive anti-solitary legislation that had been passed up to that date, the HALT Act was the first to bring a state's use of solitary
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Connecticut's solitary confinement reform law is the PROTECT Act, which includes a 15-day limit on solitary confinement, as well as a ban on solitary for vulnerable populations and a requirement that individuals held in the general population must get at least five hours of out-of-cell time per day.
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Solitary confinement has particular consequences for women that may differ from the way it affects men. Rates of solitary confinement for women in the United States are roughly comparable to those for men, with about 20% of female prisoners reported to have been in solitary confinement at some point
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Showing that solitary confinement constitutes cruel and unusual punishment has proven difficult for inmates and their attorneys. The Supreme Court requires 'extreme deprivations' in order to have merits for a 'conditions-of-confinement claim' and courts have also held that inmates are only protected
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supported solitary confinement as an alternative form of punishment. At the time it was meant to provide a prisoner with solitude "to reflect on his misdeeds" and restore his relationship with God. Solitary confinement was intended as an alternative to public floggings which were common at the time.
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and violence. To substantiate this conclusion, she cites two quantitative research based studies that support this nexus and counters those who argue that solitary confinement deters recidivism. Daniel Mears and William Bales "compared recidivism rates by matching…prisoners who were incarcerated in
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From studying conditions at Pelican Bay, researchers argue that long-term social isolation "carries major psychiatric risks." Prisoners are susceptible to developing mental illnesses because they are confined to coffin-like conditions and denied access to basic health services. Illnesses range from
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investigation found that over 1,000 people had been put in solitary for disciplinary infractions that were ineligible for placement in solitary under HALT, and that more than half of the state's solitary confinement population had been held in solitary for longer than the 15 days specified by HALT.
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when it was first passed by the state legislature in 2021. However, a coalition of advocates led by Stop Solitary CT continued to push for the bill to be signed into law and succeeded the following year. Legislative testimony submitted by incarcerated people was instrumental to winning legislators'
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Over the past decade, jurisdictions across the United States have made significant progress in reducing their use of solitary confinement. While this can be partly attributed to voluntary reforms instituted by prison administrators, much of this progress has taken place due to legislation passed at
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A large portion of the court cases addressing solitary confinement have approached the practice as a violation of Eighth Amendment rights. Courts have generally agreed that solitary confinement is, indeed, a violation of the Eighth Amendment for inmates with preexisting mental illness or juveniles.
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Researchers at McGill University paid a group of male graduate students to stay in small chambers that were to replicate solitary confinement cells. This study was to conduct an experiment on sensory deprivation and how it can cause psychiatric disorders while in solitary confinement as people are
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Passed in 2019, the Isolated Confinement Restriction Act limits placements in solitary in New Jersey prisons and jails to 20 consecutive days or 30 days in a 60-day period. It also prohibits any use of solitary for pregnant people, LGBTQ+ people, and people living with mental illness, and requires
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was one of the nation's first and most prolific supermaximum-security prisons. Consisting exclusively of solitary confinement cells, the Pelican Bay Security Housing Unit (SHU) was designed to house incarcerated people in isolation for almost 23 hours a day with virtually no human contact. Sent to
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This demonstrates that the Eighth Amendment provides "greater protection" against physical injury than against mental pain. Therefore, unless a prisoner can demonstrate physical injury as a result of solitary confinement, he or she is unable to recover damages for any "mental or emotional injury"
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The effects of solitary confinement on juveniles can be highly detrimental to their growth and development. The isolation of solitary confinement can cause extreme anguish and provoke severe mental and physical health problems. Because young people are still developing, traumatic experiences like
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are perpetrated by prison culture itself. King, Steiner, and Breach question the effectiveness of these institutions and claim the violent reputation of American prisons stems from this departure from the treatment model. Supermax prisons are also scrutinized on legal and ethical bases. Scholars
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It has been shown that solitary confinement has severe mental and psychological effects on prisoners. Prisoners in SHUs are isolated for long periods of time. Instances of assault and torture against these prisoners in response to trivial things have also been cited. Social isolation housing can
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in 2018, created some restrictions on restrictive housing, which it defines as upwards of 22 hours of isolation a day. While the law does not set an absolute limit on the number of days a person can be held in solitary, it requires placement reviews every 90 days for most people in solitary and
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is another less common strategy inmates have used. The Fourteenth Amendment limits the "types of prisoners" that can be placed in solitary confinement and the time the prisoners can be confined. The due process clause within the Fourteenth Amendment also regulates solitary confinement in that
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In light of the serious, long-lasting psychological effects solitary confinement can have, inmates have argued that the mental injuries they suffer qualify as "cruel and unusual punishment." Prison officials contend that placing inmates in prolonged solitary confinement is necessary for various
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Individuals held in the Pelican Bay SHU organized a series of hunger strikes in 2011 and 2013, which have been described as the "backbone of the anti-solitary movement" in the United States. The largest of the strikes, which began in July 2013 and ended 60 days later, encompassed over 30,000
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created a report that incorporated the testimony of some juvenile inmates. Many interviewees described how their placement in solitary confinement exacerbated the stresses of being in jail or prison. Many spoke of harming themselves with staples, razors, even plastic eating utensils, having
162:). California's prison system also uses the abbreviation SHU, but it stands for Security Housing Units. In Oregon, solitary confinement units are known as Intensive Management Units (IMUs), while in Pennsylvania, they are Restricted Housing Units (RHUs). According to a 2023 report from 234:. Proving this to be the case, however, has been a difficult task for attorneys at every level of the court system. The lack of clarity of the Eighth Amendment has raised questions with the use of solitary confinement that specifically constitutes "cruel and unusual punishment." 308:
Lobel contends that the trend in U.S. supermax prisons is to not submit these reviews at all or to provide a review with a predetermined outcome to keep the prisoner in solitary confinement. If this is indeed the case, then such inmates' due process rights are violated.
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found that 11% of all Black men born in Pennsylvania between 1986 and 1989 had been held in solitary by the age of 32. The study also found that Black and Latino men in the state were 8.2 and 2.5 times more likely to be held in solitary than white men, respectively.
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prisoners must be given reviews before and during their placement in solitary confinement. Court cases made on these bases do not necessarily address any "underlying problems" of solitary confinement, but they do call for increased monitoring, hearing, and reviews.
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Furthermore, people housed in Residential Rehabilitative Units, therapeutic units created by HALT as an alternative to solitary, reported being shackled to their desks during programming and subjected to conditions virtually identical to solitary.
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Juveniles are held in solitary confinement in jails and prisons across the United States, often for days, weeks, months, or even years. There is significant controversy surrounding the use of solitary confinement in the case of juveniles.
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anxiety, clinical depression, and self-mutilation to suicidal thoughts and SHU syndrome. Yet, it is important to note that the duration of the isolation is the most important factor in determining the effects of solitary confinement.
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In the past few years, several internal committees and administrative bodies involved in the United States prison and legal systems have also begun to question solitary confinement's legality. In June 2012, for example, the
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When a prisoner is placed in a supermax, the due process requirement of meaningful periodic review requires that his or her behavior be re-evaluated at regular intervals to determine whether supermax confinement is still
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However, the Supreme Court concluded that "while there was a risk of serious psychological injury to inmates, that risk was not of 'sufficiently serious magnitude' to find a 'per se' violation of the Eighth Amendment for
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limits placements in solitary for people with serious mental illness to 72 hours. It also bans pregnant people from being placed in solitary and creates a Restrictive Housing Oversight Committee to monitor the reforms.
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after passing both chambers of the state legislature, it was reintroduced during the 2023 legislative session as AB 280. As of July 2023, AB 280 has passed the State Assembly and is awaiting a vote in the State Senate.
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prisoners placed in long-term solitary confinement". Despite recognition of the negative consequences of forced isolation in prisons, the practice of solitary confinement remains constitutional in the United States.
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federal penitentiary in Colorado. beginning in 1983. Silverstein died in late May 2019. The inmate held in solitary confinement for the longest time in the United States is Albert Woodfox, the last of the
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no Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in custody without a prior showing of physical
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may offer an avenue to improve the provision of services to the mentally ill in prisons and solitary confinement, but ipso facto improving the conditions under which all inmates in solitary confinement
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Inmates who are placed in solitary confinement "must be accorded meaningful periodic review to ensure that segregation is not a 'pretext for indefinite confinement'". As Jules Lobel, professor at the
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Juveniles in solitary confinement are routinely denied access to treatment, services, and programming required to meet their medical, psychological, developmental, social, and rehabilitative needs.
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in December 2014. Two years later, in October 2016, it expanded this ban on punitive segregation to young adults age 21 and under. This latter policy change was motivated in part by the death of
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Advocates introduced legislation to limit solitary confinement to consecutive 15 days and ban the use of solitary for vulnerable populations in 2022. Though the bill was vetoed by Governor
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has yet to definitively state whether or not solitary confinement is unconstitutional. The Supreme Court considered the constitutionality of long-term solitary confinement only once, in
264:(PLRA) further complicates inmates' ability to claim that solitary confinement's psychological damage constitutes cruel and unusual punishment. Section 1997e(e) of the PLRA states that 663:, and Stephanie Ritchie Breach, director of the Third District Youth Court, explain how while violence has always been a factor in prison life, the level of aggression is magnified in 1015: 283: 2092: 579: 2078: 1920: 321:
In recent circuit court cases, courts have ruled that solitary confinement of 305 days or more constitutes an "atypical and significant hardship" that implicates due process.
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the confinement causes. As a result, the Eighth Amendment has not always been proven to be the most effective approach to argue against the practice of solitary confinement.
1863: 117:. The current system of solitary confinement was derived originally from the Pennsylvania model which was characterized by "isolation and seclusion." Evidence has shown that 414: 231: 86: 383:
Within the US legal system, too, courts have held that the solitary confinement of the mentally ill is "cruel and unusual". In fact, David Fathi, Director of the ACLU's
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and Unlock the Box, it is estimated that more than 122,000 individuals are held in solitary confinement in state and federal prisons and local jails on any given day.
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found multiple violations of the Constitution and ADA after investigating the use of solitary confinement for mentally ill inmates in two Pennsylvania prisons. The
349: 490:. Unlock the Box is a national coalition of advocacy groups with the goal of ending prolonged solitary confinement in the United States within the next ten years. 372:
Studies have illustrated that mentally ill inmates and juveniles are two groups more severely affected by solitary confinement than other prisoners. As such, the
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Graber, Jennifer (Fall 2008). "'When Friends Had the Management It Was Entirely Different': Quakers and Calvinists in the Making of New York Prison Discipline".
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Moreover, the legislation mandates the creation of an ombudsman and advisory commission to monitor prison conditions and oversee the implementation of reforms.
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hallucinations, losing touch with reality, and having thoughts of or attempting suicide – all this while having extremely limited access to health care.
1242: 479: 19: 2313: 2031: 1052:"Calculating Torture: Analysis of Federal, State, and Local Data Showing More Than 122,000 People in Solitary Confinement in U.S. Prisons and Jails" 2010: 704: 420:
during their incarceration. However, women often experience tougher sanctions and punishments compared with similar infractions committed by men.
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Arrigo, Bruce A.; Bullock, Jennifer Leslie (December 2008). "The Psychological Effects of Solitary Confinement on Prisoners in Supermax Units".
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or punishment" under international law, many lawyers have argued that it is also the kind of "cruel and unusual punishments" prohibited by the
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less than the definition of restrictive housing specified in the law, they do not have to comply with the requirements set forth in the CJRA.
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Cassandra, Shaylor (1998). "It's Like Living in A Black Hole: Women of Color and Solitary Confinement in the Prison Industrial Complex".
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the United States female prison population, but 42.1% of the U.S. female prison population held in solitary. Another study published in
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Today, solitary confinement is a controversial form of punishment that studies suggest has long-lasting detrimental effects on inmates'
1614:"Banning Torture: Legislative Trends and Policy Solutions for Restricting and Ending Solitary Confinement throughout the United States" 667:
where all such members of the prison system are concentrated. These scholars argue that the violent nature of supermax prisons such as
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deprived of most of their senses in there. The plan was to observe these students for six weeks, but none lasted more than seven days.
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has announced that it will conduct its first review of how solitary confinement is used in federal prisons. Additionally, the
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Pizarro, Jesenia; Stenius, Vanja M. K. (June 2004). "Supermax Prisons: Their Rise, Current Practices, and Effect on inmates".
2210: 1291: 594: 582:. It has since served as a model for similar bills introduced in other states including Connecticut, Nevada, and California. 487: 451: 227: 2146: 1459: 1733: 2233:
King, Kate; Steiner, Benjamin; Breach, Stephanie R. (March 2008). "Violence in the Supermax: A Self Fulfilling Prophecy".
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Jesenia Pizarro and Vanja Stenius note that the overall constitutionality of these prisons are still quite unclear.
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Just as California's anti-solitary legislation was vetoed by Governor Newsom in 2022, the PROTECT Act was vetoed by
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have had mixed success, with solitary confinement found to constitute cruel and unusual punishment when applied to
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Shira E. Gordon, a University of Michigan Law Student, argues that solitary confinement leads to an increase in
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or another form of restrictive housing at some point during their imprisonment. Solitary confinement (sometimes
1988: 1465:. Association of State Correctional Administrators and the Arthur Liman Public Interest Program. September 2020 668: 660: 622: 585:
Since the passage of HALT, New York State prisons have routinely thwarted key provisions of the legislation. A
499: 395: 187: 75: 1103: 2054:"Assessing the Early Months of Implementation of the HALT Solitary Confinement Law in New York State Prisons" 1864:"Writing from their prison cells, the incarcerated submit testimony about their time in solitary confinement" 384: 35:, upwards of 20 percent of state and federal prison inmates and 18 percent of local jail inmates are kept in 1793:"Unbroken Spirit: Pelican Bay, California Prisoner Hunger Strikes, Family Uprisings, and Learning to Listen" 1187: 656: 192: 138:. Shortly after, New York decided to include solitary confinement and inmate labor into their penal system. 1153: 751:"Nearly 20 Percent of Prison and Jail Inmates Spent Time in Segregation or Solitary Confinement in 2011–12" 1921:"Massachusetts Department of Correction Gives a Lesson in How to Get Around Solitary Confinement Reforms" 1814: 330:
of Alabama School of Law, suggests that those who challenge solitary confinement do so in context of the
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Opponents of solitary confinement have argued with varying success that the practice violates prisoners'
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Solitary confinement first arose in the United States in the 1700s among religious groups like the
2289: 2272: 2252: 2235: 1734:"Regulating Prisons of the Future: A Psychological Analysis of Supermax and Solitary Confinement" 1564: 975: 907: 455: 402: 287: 170: 2114:"Kalief Browder's Suicide Brought Changes to Rikers. Now It Has Led to a $ 3 Million Settlement" 1076: 2032:"Class Action Lawsuit: New York Prisons Violate Restrictions on Prolonged Solitary Confinement" 1553:
Growing Up Locked Down: Youth in Solitary Confinement in Jails and Prisons in the United States
2121: 1568: 1523: 1292:"Torture in US Jails and Prisons: An Analysis of Solitary Confinement Under International Law" 899: 253: 2281: 2244: 2011:"Solitary by Another Name: How State Prisons Are Using 'Therapeutic' Units to Evade Reforms" 1513: 1505: 967: 891: 829: 474:
Organizations in the United States working to end the use of long-term solitary include the
209: 148: 145:, solitary confinement is known as the Special Housing Unit (SHU), pronounced like "shoe" ( 999: 750: 664: 114: 40: 1420: 845: 1989:"Lesser Infractions Aren't Supposed to Land You in Solitary Confinement. They Do Anyway" 1501: 376:
and juveniles has been upheld as cruel and unusual in both international and US courts.
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The inmate held in solitary confinement for the longest time in U.S. federal prison was
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magazine also cites one inmate there who "recently marked his 40th year in solitary".
2307: 2256: 1237: 1011: 1002:(from the Bureau of Prisons, US Department of Justice website. Retrieved 1 May 2008.) 979: 805: 724: 611: 552: 110: 2293: 1643:"State Prisons Are Routinely Violating New York's Landmark Solitary Confinement Law" 911: 1792: 1158: 694: 522: 401:
Juveniles who are charged as adults and placed in adult prisons are usually put in
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solitary confinement may have a profound negative effect on their rehabilitation.
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announced that it had ended punitive segregation for adolescents incarcerated on
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Pullen-Blasnik, Hannah; Simes, Jessica T.; Western, Bruce (26 November 2021).
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partnered with the lead organizers of the strike on a class action lawsuit,
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against "certain kinds of extreme deprivations" by the Eighth Amendment. In
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held its first hearing on solitary confinement. Likewise, as of 2013, the
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confinement in line with the 15-day limit mandated by the United Nations'
2097: 1599: 1080: 1966:"New York State Passes the Nation's Strongest Anti-Solitary Legislation" 1688: 1029: 971: 884:
International Journal of Offender Therapy & Comparative Criminology
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and solitary confinement in place of other forms of punishment such as
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in the United States developed under two separate systems known as the
59: 727:(form of torture involving solitary confinement in an overheated room) 394:, challenged the conditions of the Security Housing Unit (SHU) in the 1666:"Solitary Confinement Still A Concern At Essex County Prison: Report" 699: 1891:"In their own words: Prisoners testify on solitary confinement bill" 569:
mental health evaluations before and during placements in solitary.
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The Criminal Justice Reform Act (CJRA), signed into law by Governor
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Agency (ICE) has also revised segregation procedures for detainees.
1596:"Solitary confinement: New York bans prison isolation over 15 days" 63: 18: 1943:"Gov. Murphy Signs Isolated Confinement Restriction Act Into Law" 731:
List of United States Supreme Court cases involving mental health
1560: 208:. Despite the long history of litigation over the practice, the 1421:"Use of Restrictive Housing in U.S. Prisons and Jails, 2011-12" 1107: 338:
When claims under the Eighth and Fourteenth Amendments fail,
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Kiebala, Valerie; Rodriguez, Sal; Zhu, Mirilla (June 2023).
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Kiebala, Valerie; Rodriguez, Sal; Zhu, Mirilla (June 2023).
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Litigating against solitary confinement on the basis of the
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Institution Supplement – Visiting Regulations, USP McCreary
2193:"Children in isolation: the solitary confinement of youth" 1104:"'Terrible Tommy' spends 27 years in solitary confinement" 226:
Since solitary confinement has been designated as "cruel,
151: 1388:"Solitary Confinement: The Law Today and the Way Forward" 659:, Benjamin Steiner, professor of Criminal Justice at the 655:
Kate King, professor and director of Criminal Justice at
1129:"Killer held in solitary confinement for 35 years dies" 1016:
California Department of Corrections and Rehabilitation
1689:"Solitary Confinement in the United States: The Facts" 1460:"Time-in-Cell 2019: A Snapshot of Restrictive Housing" 1030:"Solitary Confinement in the United States: The Facts" 2199:: 1–80 – via George Mason University Libraries. 1442:
New England Journal on Criminal and Civil Confinement
1340:"Prolonged Solitary Confinement and the Constitution" 1238:"Solitary Confinement, Public Safety, and Recidivism" 186:
from 1972 to 2016. A May 2013 report on California's
1154:"37 years of solitary confinement: the Angola three" 1486:"The Population Prevalence of Solitary Confinement" 2059:. Correctional Association of New York. March 2023 1641:Gelardi, Chris; Brown, Emily (12 September 2022). 415:Solitary confinement of women in the United States 87:Eighth Amendment to the United States Constitution 2211:"What Does Solitary Confinement Do To Your Mind?" 23:Original bed inside solitary confinement cell in 825:"Solitary Confinement: Torture, Pure and Simple" 16:Form of strict imprisonment in the United States 1763: 1761: 1759: 1381: 1379: 1377: 1375: 1373: 1371: 1369: 1367: 336: 301: 266: 1285: 1231: 1229: 1227: 1225: 1057:. Solitary Watch and Unlock the Box. June 2023 1283: 1281: 1279: 1277: 1275: 1273: 1271: 1269: 1267: 1265: 1223: 1221: 1219: 1217: 1215: 1213: 1211: 1209: 1207: 1205: 1181:Ridgeway, James; Casella, Jean (8 May 2013). 8: 1768:Lin, Yen-Tung; Baltay, Luke (18 July 2023). 1333: 1331: 1329: 1327: 1325: 1323: 1321: 1319: 1317: 846:"Is Long-Term Solitary Confinement Torture?" 374:solitary confinement of mentally ill inmates 1545: 1543: 1541: 1539: 1537: 480:National Religious Campaign Against Torture 1012:Visitors, State Prison, Corcoran (CSP-COR) 925:Griest, Stephanie Elizondo (Spring 2012). 1914: 1912: 1517: 1183:"America's 10 Worst Prisons: Pelican Bay" 598:the early months of HALT implementation. 78:political period in the 1980s and 1990s. 2170:"Kalief Browder would turn 30 this week" 877: 875: 873: 871: 869: 867: 865: 863: 861: 278:Due process and the Fourteenth Amendment 97:but deemed permissible for sane adults. 2228: 2226: 2224: 1919:Quandt, Katie Rose (20 November 2019). 1636: 1634: 801:"The case against solitary confinement" 742: 705:History of United States prison systems 332:Americans with Disabilities Act of 1990 126:In 1818, New York reformer and Friend, 818: 816: 608:New York City Department of Correction 362:US Immigration and Customs Enforcement 297:University of Pittsburgh School of Law 173:, held in solitary confinement at the 1795:. University of California, Riverside 927:"The Torture of Solitary Confinement" 767:from the original on 19 October 2020. 7: 1964:Riccobene, Veronica (2 April 2021). 799:Wykstra, Stephanie (17 April 2019). 543:support for the bill in both years. 380:inmates and juveniles respectively. 1419:Beck, Allen J. (October 23, 2015). 1077:"Supermax: A Clean Version Of Hell" 823:Boyd, J. Wesley (15 January 2018). 761:United States Department of Justice 143:United States federal prison system 1987:Gelardi, Chris (24 October 2022). 1732:Haney, Craig; Lynch, Mona (1997). 1018:website. (Retrieved 12 June 2016.) 785:American Psychological Association 476:American Friends Service Committee 368:Mentally ill inmates and juveniles 14: 2314:Penal system in the United States 2009:Gelardi, Chris (5 October 2022). 1889:Lyons, Kelan (26 December 2022). 325:Alternative litigation techniques 2034:. ACLU of New York. 5 April 2023 1738:NYU Rev. Law & Social Change 1386:Cockrell, John F. (March 2013). 516:Ashker v. Governor of California 512:Center for Constitutional Rights 147: 2112:Weiser, Benjamin (2019-01-24). 1945:. ACLU New Jersey. 11 July 2019 844:Gawande, Atul (23 March 2009). 62:, who thought isolation with a 2145:Factora, James (8 June 2021). 1897:. The Connecticut News Project 1870:. The Connecticut News Project 1862:Lyons, Kelan (22 March 2021). 1839:Zhu, Mirilla (18 March 2022). 1820:. Connecticut General Assembly 1619:. Unlock the Box. January 2023 1338:Lobel, Jules (December 2008). 595:New York Civil Liberties Union 488:American Civil Liberties Union 452:American Civil Liberties Union 334:(ADA). Cockrell reasons that 228:inhuman or degrading treatment 1: 1664:Kiefer, Eric (13 July 2023). 1296:Vienna J. On Int'l Const. Law 1152:Erwin James (10 March 2010). 710:Isolation to facilitate abuse 498:Opened in 1989, California's 350:US Senate Judiciary Committee 1426:Bureau of Justice Statistics 756:Bureau of Justice Statistics 602:New York City: Rikers Island 262:Prison Litigation Reform Act 184:Louisiana State Penitentiary 91:cruel and unusual punishment 1550:Kysel, Ian (October 2012). 1393:Law & Psychology Review 1290:Conley, Anna (April 2013). 49:punitive segregation (PSEG) 2330: 2168:Lau, Tandy (27 May 2023). 1791:Camacho, Angelica (2017). 778:Weir, Kirsten (May 2012). 424:Black and Latino Americans 412: 33:United States penal system 2191:Birckhead, Tamar (2015). 2172:. New York Amsterdam News 1236:Gordon, Shira E. (2014). 715:Prison abolition movement 2286:10.1177/0032885504265080 2249:10.1177/0032885507311000 1179:The inmate is not named. 896:10.1177/0306624X07309720 669:Pelican Bay State Prison 661:University of Cincinnati 500:Pelican Bay State Prison 396:Pelican Bay State Prison 358:US Department of Justice 188:Pelican Bay State Prison 657:Murray State University 385:National Prison Project 1815:"Public Act No. 22-18" 1510:10.1126/sciadv.abj1928 1243:U. Mich. J. Law Reform 780:"Alone, in 'the hole'" 629:Scrutiny and criticism 466:Legislation and reform 345: 306: 271: 28: 634:Psychological effects 206:constitutional rights 22: 932:The Wilson Quarterly 700:Prison#Control units 354:US Bureau of Prisons 284:Fourteenth Amendment 95:mentally ill inmates 83:psychological health 37:solitary confinement 25:Franklin County Jail 2197:Law Journal Library 2081:. 17 December 2014. 1502:2021SciA....7.1928P 763:. 23 October 2015. 390:One landmark case, 315:Wilkinson v. Austin 215:Wilkinson v. Austin 115:Pennsylvania system 2273:The Prison Journal 2236:The Prison Journal 2118:The New York Times 1565:Human Rights Watch 998:2010-12-03 at the 972:10.1353/qkh.0.0011 456:Human Rights Watch 403:protective custody 171:Thomas Silverstein 45:protective custody 29: 1574:978-1-56432-949-3 1083:. 11 October 2007 254:Farmer v. Brennan 182:, in solitary in 2321: 2298: 2297: 2267: 2261: 2260: 2230: 2219: 2218: 2207: 2201: 2200: 2188: 2182: 2181: 2179: 2177: 2165: 2159: 2158: 2156: 2154: 2142: 2136: 2135: 2133: 2132: 2109: 2103: 2102: 2089: 2083: 2082: 2075: 2069: 2068: 2066: 2064: 2058: 2050: 2044: 2043: 2041: 2039: 2028: 2022: 2021: 2019: 2017: 2006: 2000: 1999: 1997: 1995: 1984: 1978: 1977: 1975: 1973: 1968:. Solitary Watch 1961: 1955: 1954: 1952: 1950: 1939: 1933: 1932: 1930: 1928: 1923:. Solitary Watch 1916: 1907: 1906: 1904: 1902: 1886: 1880: 1879: 1877: 1875: 1859: 1853: 1852: 1850: 1848: 1843:. Solitary Watch 1836: 1830: 1829: 1827: 1825: 1819: 1811: 1805: 1804: 1802: 1800: 1788: 1782: 1781: 1779: 1777: 1772:. Solitary Watch 1765: 1754: 1753: 1751: 1749: 1729: 1723: 1722: 1720: 1718: 1713:. Unlock the Box 1707: 1701: 1700: 1698: 1696: 1691:. Solitary Watch 1684: 1678: 1677: 1675: 1673: 1661: 1655: 1654: 1652: 1650: 1645:. New York Focus 1638: 1629: 1628: 1626: 1624: 1618: 1610: 1604: 1603: 1592: 1586: 1585: 1583: 1581: 1558: 1547: 1532: 1531: 1521: 1496:(48): eabj1928. 1490:Science Advances 1481: 1475: 1474: 1472: 1470: 1464: 1456: 1450: 1449: 1437: 1431: 1430: 1416: 1410: 1409: 1407: 1405: 1383: 1362: 1361: 1359: 1357: 1335: 1312: 1311: 1309: 1307: 1287: 1260: 1259: 1257: 1255: 1233: 1200: 1199: 1197: 1195: 1177: 1171: 1170: 1168: 1166: 1149: 1143: 1142: 1140: 1139: 1125: 1119: 1118: 1116: 1114: 1102:Stephanie Chen. 1099: 1093: 1092: 1090: 1088: 1073: 1067: 1066: 1064: 1062: 1056: 1048: 1042: 1041: 1039: 1037: 1032:. Solitary Watch 1025: 1019: 1009: 1003: 990: 984: 983: 955: 949: 948: 946: 944: 922: 916: 915: 879: 856: 855: 841: 835: 834: 830:Psychology Today 820: 811: 810: 796: 790: 789: 775: 769: 768: 747: 665:supermax prisons 431:Science Advances 232:Eighth Amendment 222:Eighth Amendment 210:US Supreme Court 161: 160: 157: 156: 153: 53:room restriction 2329: 2328: 2324: 2323: 2322: 2320: 2319: 2318: 2304: 2303: 2302: 2301: 2269: 2268: 2264: 2232: 2231: 2222: 2209: 2208: 2204: 2190: 2189: 2185: 2175: 2173: 2167: 2166: 2162: 2152: 2150: 2144: 2143: 2139: 2130: 2128: 2111: 2110: 2106: 2091: 2090: 2086: 2077: 2076: 2072: 2062: 2060: 2056: 2052: 2051: 2047: 2037: 2035: 2030: 2029: 2025: 2015: 2013: 2008: 2007: 2003: 1993: 1991: 1986: 1985: 1981: 1971: 1969: 1963: 1962: 1958: 1948: 1946: 1941: 1940: 1936: 1926: 1924: 1918: 1917: 1910: 1900: 1898: 1888: 1887: 1883: 1873: 1871: 1861: 1860: 1856: 1846: 1844: 1838: 1837: 1833: 1823: 1821: 1817: 1813: 1812: 1808: 1798: 1796: 1790: 1789: 1785: 1775: 1773: 1767: 1766: 1757: 1747: 1745: 1731: 1730: 1726: 1716: 1714: 1709: 1708: 1704: 1694: 1692: 1686: 1685: 1681: 1671: 1669: 1663: 1662: 1658: 1648: 1646: 1640: 1639: 1632: 1622: 1620: 1616: 1612: 1611: 1607: 1602:. 2 April 2021. 1594: 1593: 1589: 1579: 1577: 1575: 1556: 1549: 1548: 1535: 1483: 1482: 1478: 1468: 1466: 1462: 1458: 1457: 1453: 1439: 1438: 1434: 1418: 1417: 1413: 1403: 1401: 1385: 1384: 1365: 1355: 1353: 1337: 1336: 1315: 1305: 1303: 1289: 1288: 1263: 1253: 1251: 1235: 1234: 1203: 1193: 1191: 1180: 1178: 1174: 1164: 1162: 1151: 1150: 1146: 1137: 1135: 1127: 1126: 1122: 1112: 1110: 1101: 1100: 1096: 1086: 1084: 1075: 1074: 1070: 1060: 1058: 1054: 1050: 1049: 1045: 1035: 1033: 1027: 1026: 1022: 1010: 1006: 1000:Wayback Machine 991: 987: 957: 956: 952: 942: 940: 924: 923: 919: 881: 880: 859: 843: 842: 838: 822: 821: 814: 798: 797: 793: 777: 776: 772: 749: 748: 744: 739: 691: 678: 653: 651:Prison violence 636: 631: 623:Layleen Polanco 604: 575: 566: 549: 532: 496: 468: 440: 426: 417: 411: 392:Madrid v. Gomez 370: 327: 280: 224: 202: 150: 146: 103: 41:euphemistically 17: 12: 11: 5: 2327: 2325: 2317: 2316: 2306: 2305: 2300: 2299: 2280:(2): 248–264. 2262: 2220: 2202: 2183: 2160: 2137: 2104: 2084: 2070: 2045: 2023: 2001: 1979: 1956: 1934: 1908: 1881: 1854: 1831: 1806: 1783: 1755: 1724: 1702: 1679: 1656: 1630: 1605: 1587: 1573: 1533: 1476: 1451: 1448:: 385:390–420. 1432: 1411: 1363: 1313: 1261: 1201: 1172: 1144: 1120: 1094: 1068: 1043: 1020: 1004: 985: 960:Quaker History 950: 917: 890:(6): 622–640. 857: 851:The New Yorker 836: 812: 791: 770: 741: 740: 738: 735: 734: 733: 728: 722: 720:Single-celling 717: 712: 707: 702: 697: 690: 687: 677: 674: 652: 649: 635: 632: 630: 627: 616:Kalief Browder 603: 600: 587:New York Focus 574: 571: 565: 562: 548: 545: 531: 528: 495: 492: 484:Solitary Watch 467: 464: 439: 436: 425: 422: 413:Main article: 410: 407: 369: 366: 326: 323: 279: 276: 223: 220: 201: 198: 164:Solitary Watch 130:, lobbied for 102: 99: 76:tough on crime 72:rehabilitation 66:would lead to 27:, Pennsylvania 15: 13: 10: 9: 6: 4: 3: 2: 2326: 2315: 2312: 2311: 2309: 2295: 2291: 2287: 2283: 2279: 2275: 2274: 2266: 2263: 2258: 2254: 2250: 2246: 2243:(1): 144–68. 2242: 2238: 2237: 2229: 2227: 2225: 2221: 2216: 2212: 2206: 2203: 2198: 2194: 2187: 2184: 2171: 2164: 2161: 2148: 2141: 2138: 2127: 2123: 2119: 2115: 2108: 2105: 2100: 2099: 2094: 2088: 2085: 2080: 2074: 2071: 2055: 2049: 2046: 2033: 2027: 2024: 2012: 2005: 2002: 1990: 1983: 1980: 1967: 1960: 1957: 1944: 1938: 1935: 1922: 1915: 1913: 1909: 1896: 1892: 1885: 1882: 1869: 1865: 1858: 1855: 1842: 1835: 1832: 1816: 1810: 1807: 1794: 1787: 1784: 1771: 1764: 1762: 1760: 1756: 1743: 1739: 1735: 1728: 1725: 1712: 1706: 1703: 1690: 1683: 1680: 1667: 1660: 1657: 1644: 1637: 1635: 1631: 1615: 1609: 1606: 1601: 1597: 1591: 1588: 1576: 1570: 1566: 1562: 1555: 1554: 1546: 1544: 1542: 1540: 1538: 1534: 1529: 1525: 1520: 1515: 1511: 1507: 1503: 1499: 1495: 1491: 1487: 1480: 1477: 1461: 1455: 1452: 1447: 1443: 1436: 1433: 1428: 1427: 1422: 1415: 1412: 1399: 1395: 1394: 1389: 1382: 1380: 1378: 1376: 1374: 1372: 1370: 1368: 1364: 1351: 1347: 1346: 1345:J. Const. Law 1341: 1334: 1332: 1330: 1328: 1326: 1324: 1322: 1320: 1318: 1314: 1301: 1297: 1293: 1286: 1284: 1282: 1280: 1278: 1276: 1274: 1272: 1270: 1268: 1266: 1262: 1249: 1245: 1244: 1239: 1232: 1230: 1228: 1226: 1224: 1222: 1220: 1218: 1216: 1214: 1212: 1210: 1208: 1206: 1202: 1190: 1189: 1184: 1176: 1173: 1161: 1160: 1155: 1148: 1145: 1134: 1130: 1124: 1121: 1109: 1105: 1098: 1095: 1082: 1078: 1072: 1069: 1053: 1047: 1044: 1031: 1024: 1021: 1017: 1013: 1008: 1005: 1001: 997: 994: 989: 986: 981: 977: 973: 969: 965: 961: 954: 951: 938: 934: 933: 928: 921: 918: 913: 909: 905: 901: 897: 893: 889: 885: 878: 876: 874: 872: 870: 868: 866: 864: 862: 858: 853: 852: 847: 840: 837: 832: 831: 826: 819: 817: 813: 808: 807: 802: 795: 792: 787: 786: 781: 774: 771: 766: 762: 758: 757: 752: 746: 743: 736: 732: 729: 726: 723: 721: 718: 716: 713: 711: 708: 706: 703: 701: 698: 696: 693: 692: 688: 686: 683: 675: 673: 670: 666: 662: 658: 650: 648: 644: 640: 633: 628: 626: 624: 621:The death of 619: 617: 613: 612:Rikers Island 609: 601: 599: 596: 591: 588: 583: 581: 580:Mandela Rules 572: 570: 563: 561: 557: 554: 553:Charlie Baker 547:Massachusetts 546: 544: 541: 536: 529: 527: 524: 519: 517: 513: 510:In 2012, the 508: 504: 501: 493: 491: 489: 485: 481: 477: 472: 465: 463: 460: 457: 453: 448: 444: 437: 435: 432: 423: 421: 416: 408: 406: 404: 399: 397: 393: 388: 386: 381: 377: 375: 367: 365: 363: 359: 355: 351: 344: 341: 335: 333: 324: 322: 319: 317: 316: 310: 305: 300: 298: 292: 289: 285: 277: 275: 270: 265: 263: 258: 256: 255: 248: 245: 239: 235: 233: 229: 221: 219: 217: 216: 211: 207: 199: 197: 195: 194: 189: 185: 181: 176: 172: 167: 165: 159: 144: 139: 137: 133: 129: 124: 120: 116: 112: 111:Auburn system 108: 100: 98: 96: 92: 88: 84: 79: 77: 73: 69: 65: 61: 56: 54: 50: 46: 42: 38: 34: 26: 21: 2277: 2271: 2265: 2240: 2234: 2214: 2205: 2196: 2186: 2174:. 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Patch.com 1133:Google News 1014:, from the 530:Connecticut 454:(ACLU) and 288:due process 128:Thomas Eddy 2131:2019-11-19 1711:"About Us" 1138:2019-05-26 939:(2): 22–29 737:References 682:recidivism 676:Recidivism 564:New Jersey 540:Ned Lamont 494:California 486:, and the 304:warranted. 123:Calvinists 89:'s ban on 68:repentance 2257:145161822 2215:FRONTLINE 2126:0362-4331 1895:CT Mirror 1868:CT Mirror 1744:: 478–558 1400:: 211–227 1302:: 415–453 980:159920151 438:Juveniles 2308:Category 2294:35051886 2098:Politico 1600:BBC News 1559:. U.S.: 1528:34826243 1254:14 March 1081:CBS News 996:Archived 943:11 March 912:10433547 904:18025074 765:Archived 689:See also 573:New York 340:Title II 200:Legality 2176:21 July 2153:21 July 2063:21 July 2038:21 July 2016:21 July 1994:21 July 1972:21 July 1949:28 June 1927:21 July 1901:21 July 1874:21 July 1847:21 July 1824:21 July 1799:21 July 1776:21 July 1748:5 March 1717:21 July 1695:21 July 1672:21 July 1649:21 July 1623:28 June 1580:12 June 1519:8626064 1498:Bibcode 1194:3 April 1165:3 April 1113:3 April 1087:3 April 1061:28 June 1036:13 July 269:injury. 141:In the 136:hanging 119:Quakers 101:History 60:Quakers 43:called 31:In the 2292:  2255:  2149:. them 2124:  1571:  1563:& 1526:  1516:  1469:9 July 978:  910:  902:  478:, the 2290:S2CID 2253:S2CID 2057:(PDF) 1818:(PDF) 1617:(PDF) 1557:(PDF) 1463:(PDF) 1404:1 May 1356:1 May 1306:1 May 1055:(PDF) 976:S2CID 908:S2CID 409:Women 343:live. 64:Bible 2178:2023 2155:2023 2122:ISSN 2065:2023 2040:2023 2018:2023 1996:2023 1974:2023 1951:2023 1929:2023 1903:2023 1876:2023 1849:2023 1826:2023 1801:2023 1778:2023 1750:2013 1719:2023 1697:2023 1674:2023 1651:2023 1625:2023 1582:2016 1569:ISBN 1561:ACLU 1524:PMID 1471:2023 1406:2014 1358:2014 1308:2014 1256:2014 1196:2014 1167:2014 1115:2014 1089:2014 1063:2023 1038:2023 945:2013 900:PMID 606:The 593:The 450:The 286:and 260:The 121:and 113:and 105:The 70:and 2282:doi 2245:doi 1514:PMC 1506:doi 1108:CNN 968:doi 892:doi 806:Vox 725:Box 312:In 244:all 190:in 51:or 2310:: 2288:. 2278:84 2276:. 2251:. 2241:88 2239:. 2223:^ 2213:. 2195:. 2120:. 2116:. 2095:. 1911:^ 1893:. 1866:. 1758:^ 1742:23 1740:. 1736:. 1633:^ 1598:. 1567:. 1536:^ 1522:. 1512:. 1504:. 1492:. 1488:. 1446:24 1444:. 1423:. 1398:37 1396:. 1390:. 1366:^ 1350:11 1348:. 1342:. 1316:^ 1298:. 1294:. 1264:^ 1248:47 1246:. 1240:. 1204:^ 1185:. 1156:. 1131:. 1106:. 1079:. 974:. 964:97 962:. 937:36 935:. 929:. 906:. 898:. 888:52 886:. 860:^ 848:. 827:. 815:^ 803:. 782:. 759:. 753:. 482:, 155:uː 47:, 2296:. 2284:: 2259:. 2247:: 2217:. 2180:. 2157:. 2134:. 2101:. 2067:. 2042:. 2020:. 1998:. 1976:. 1953:. 1931:. 1905:. 1878:. 1851:. 1828:. 1803:. 1780:. 1752:. 1721:. 1699:. 1676:. 1653:. 1627:. 1584:. 1530:. 1508:: 1500:: 1494:7 1473:. 1429:. 1408:. 1360:. 1310:. 1300:7 1258:. 1198:. 1169:. 1141:. 1117:. 1091:. 1065:. 1040:. 982:. 970:: 947:. 914:. 894:: 854:. 833:. 809:. 788:. 158:/ 152:ʃ 149:/

Index


Franklin County Jail
United States penal system
solitary confinement
euphemistically
Quakers
Bible
repentance
rehabilitation
tough on crime
psychological health
Eighth Amendment to the United States Constitution
cruel and unusual punishment
mentally ill inmates
penal system
Auburn system
Pennsylvania system
Quakers
Calvinists
Thomas Eddy
inmate labor
hanging
United States federal prison system
/ʃ/
Solitary Watch
Thomas Silverstein
ADX Florence
Angola Three
Louisiana State Penitentiary
Pelican Bay State Prison

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