Running head: SOLITARY CONFINEMENT 1

Solitary Confinement: Buried Alive

Adriana D. Peoples

First Colonial High School Legal Studies Academy

SOLITARY CONFINEMENT 2

Abstract

This paper will look inside of prisons with a focus on solitary confinement. This paper will delve

into the history of solitary confinement and give a brief timeline of how solitary confinement

came to be. Thereafter, it will cover the states of confinement and the social conditions of

isolation to inform readers of the living conditions while in isolation. While discussing the state

of confinement the paper will cover the effects isolation has on prisoners.This paper will move

on to discuss one of the worst solitary confinement units in the nation at The Pelican Bay State

Prison. While discussing Pelican Bay the paper will cover the lawsuits and other incidents that

occured within that prisons isolation unit. Furthermore, the paper will cover the laws governing

isolation, case law, and compare the american isolation units to those of other countries. This

paper will then cover the topic of juveniles in solitary confinement discussing how they are

effected and personal testimonies from youth who have been in confinement. Lastly, the paper

will cover the reforms coming with juvenile solitary confinement units as well as adult

confinement units.
SOLITARY CONFINEMENT 3

Solitary Confinement: Protection or Abuse

A room the size of a horse stable, maybe even smaller, a thin mattress, one blanket, a

toilet, and the clothes you came in with, that's all you have. Human to human contact cut to a

bare minimum, and your chances of stepping outside stripped away. It’s just you and the wall,

with no clear time when you will be reintegrated with the prison society. This is your life for the

next few weeks, months, maybe even years. Now imagine you're 15. No human deserves this

treatment even if they are criminals at any age whether it be 15 or 50; it is inhumane and has

severe and damaging effects on a person. Solitary Confinement (SC) is defined as the state of

being kept alone in a prison cell away from other prisoners​ ("Solitary Confinement Facts,"

2016)​. Other terms for solitary confinement that are used interchangeably within different jail

systems are isolation, the SHU which stands for special housing unit​ (Weber, 2015)​, the hole,

administrative regulation, ​Supermax Prisons, MCU which stands for management control unit,

and​ voluntary or involuntary protective custody. It is often used as a form of punishment for

inmates who commit prison violations, while others may be sent into confinement upon entering

the jail because they are deemed a threat to the prison society​ ​("Solitary Confinement Facts,"

2016). Each jail system runs their confinement centers in their own way according to how they

see fit. ​The abuse of solitary confinement by prison systems depletes the mental and physical

health conditions of prisoners by placing them in an environment where their well being is

neglected.

History of Solitary Confinement

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Solitary confinement had the original intentions to reform prisoners and improve their

behaviors. The first usage of solitary confinement in the United States is documented to have

begun in 1829. The first use was an experiment formed off of the Quaker belief. It was intended

to prove that isolation would reform the prisoner and change their views and behaviour. This

experiment was carried out at the Eastern Penitentiary in Philadelphia. As a result of the

experiment, the prisoners reacted completely different from what was expected. They were said

to have increased suicide attempts and other forms of self harm. After the experiment, the usage

of isolation does not progress. In 1934 the Alcatraz isolation system was on the rise and their

prisoners were allotted a piece of bread and water which is given through the door. While in

isolation in Alcatraz, prisoners were not allowed to have personal items even clothes. Clothes

and personal items were given to the inmates in a less restrictive but still conformed form of

isolation known as “D-block,” (Sullivan, 2006).

In Marion Illinois, 1983, a prison is the first to institute a 23 hour restrictive isolation

system where the prisoners were allowed out of their cell for an hour a day. Pelican Bay Prison,

the most grim prison, was built and begins running in 1989. It is intended to be a supermax

facility used to hold violent inmates and other serious offenders. With its intentions and agenda

in mind the prison was built without many prison “luxuries” such as a cafeteria or prison yard.

The construction was designed to better facilitate a 23 hour restrictive isolation. In 1995 a judge

deemed the conditions at Pelican Bay Prison as barely tolerable for a human to withstand but

there was a lack of constitutional ruling to hinder the unit. As 1999 approached the use of 23

hour restriction is now in 30 states. In 2005 Daniel P. Mears concludes that out of the usage in 40

states there are at the least 25,000 prisoners in isolation. He also finds that 0.5% to 20% of
SOLITARY CONFINEMENT 5

inmates from the total population are placed in a supermax facility. The use of solitary

confinement began its rise when more prison systems used it as a way to try and restrict and

reduce the amount of violence in prisons​ (Sullivan, 2006).

States of Confinement

The basics of solitary confinement remain the same throughout most prison systems. The

prisoners are allotted an hour to an hour and a half out from their cell, and their cells are often

times windowless and only contain a toilet, a thin mattress, and a thin blanket. If the prisoners

are lucky and the guards are nice, they are allowed limited reading materials and personal

property ​("Ashker v. Governor of California," 2012).

Social Conditions

Inmates who are placed in the hole are restricted to minimal human contact. In the

Pelican Bay State Prison the inmates are restricted to no phone calls, visits, rec time, or

educational programming ("Ashker v. Governor of California," 2012). With the restrictions

imposed on the inmates, the only way they communicate with another person is when the guards

come to bring food or take them to a shower. Even in those moments guards hold conversations

that are necessary to complete a task. In other prisons the inmates are allowed rec time, during

this time they still do not experience human interaction; they are alone. Their loneliness

continues throughout the day, from meal time to shower time​ (Graves, 2015)​. The prisoner's

sense of privacy is taken away. In a Texas jail the inmates in solitary confinement must strip

down to be inspected every time they are transported, whether if it is from their room to the

bathroom or the recreation yard (Graves, 2015). The medical attention for inmates in the hole is

only given when deemed extremely necessary or if the inmate is on a prescribed drug by the
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medical staff. For minor medical needs such as headaches or stomach aches the medical staff is

not called in and inmates are forced to cope and deal with these problem on their own.

Effects

Solitary confinement stresses a person mentally and physically. Being locked in a

room by yourself for well over a majority of the day is taxing on the body of a inmate. Studies

have been done to show the effects that solitary confinement has on a person both physically and

mentally. Harry Harlow, a 1950 psychologist, conducted a study that put monkeys in a state of

confinement. By the second day the monkeys demeanor had begun to show hopelessness and

despair. He was also able to discover that the monkeys who were kept in isolation were disturbed

and reacted poorly to isolation. Those who were not caged for an extended period of time were

able to eventually readjust. Those who were held the longest begun to lose their social abilities

(Breslow, 2014)​. In 1951 McGill University conducted a study as well. This study was focused

towards sensory deprivation. Male graduate students were placed in a room with only a bed and

they were only allowed to use the bathroom. The subjects were forced to wear goggles, gloves,

and earbuds to limit all of their systems. The study was not able to be carried out completely

because all of the males began to lose the ability to think clearly after a week (Breslow, 2014). A

psychiatrist by the name of Stuart Grassian interviews prisoners in solitary confinement. Several

of the inmates that he interviewed showed signs of being suicidal or psychotic. Grassian believes

that solitary confinement causes psychosis and other side effects not good for the human brain.

These effects range from diminished impulse control to unhealthy obsessions. Solitary

confinement has been proven to make inmates a larger danger to themselves and the community,

given they are released. A study in a California prison found that over five years inmates in
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solitary are responsible for almost half of prison suicides. A study in 1995 found that in federal

prisons 63 percent of suicides were a result of inmates in isolation. Studies have also found that it

is difficult for inmates in isolation to adjust socially. While in isolation their social abilities

deteriorate as a result of the lack of human interaction. When prisoners are released or are

presented to interact with other people, it is difficult for them to initiate a conversation or fit in

socially (Breslow, 2014). After reviewing the effects of solitary confinement, it has become a

controversial issue in the judicial system.​U.S. Supreme Court Justice Samuel Freeman Miller

finds,

A considerable number of the prisoners fell, after even a short

confinement, into a semi-fatuous condition, from which it was next

to impossible to arouse them, and others became violently insane; others still, committed

suicide; while those who stood the ordeal better were not generally reformed, and in most

cases did not recover sufficient mental activity to be of any subsequent service to the

community.(Sullivan, 2006)

The effects of solitary confinement have caused the issue to reach the Supreme Court. Many

justices acknowledge the effects that it has on prisoners, but in many ways they believe that their

hands are tied behind their backs and they are limited to helping (Sullivan, 2006). The long term

and even short term effects of solitary confinement range from hypersensitivity to surroundings

to distortion of time. The effects go beyond the four walls. When the inmates are released, they

are expected to be able to fit into society and act normally. After being alone for so long the

inmates are physically and mentally unable to do this.

Pelican Bay Prison System

SOLITARY CONFINEMENT 8

The Pelican Bay Prison system is deemed to be the most inhumane prison system in

America. Their conditions of solitary confinement has reached an extreme. The prisoners

affected by this system display some of the most traumatic and depriving effects of solitary

confinement. Pelican Bay or “ The Bay” houses about 1,500 occupants within the SHU ​(Casella

& Ridgeway, n.d.).

Conditions Within Pelican Bay

Within the Pelican Bay Prison SHU inmates survive with the bare minimum. The SHU

and “The Bay” runs on a 22.5 hour system. The prisoners are held in their windowless 7x11

cells, with a light that never goes off for 22 and a half hours, and with the time that they are out

of their cell they bathe and spend time in the yard. The yard at Pelican Bay is a concrete area

where the prisoners get to exercise. While an inmate is in the yard, they have no contact with

other inmates. They spend their time alone until they are taken back in their cell to end or

continue their day. The inmates are limited to human contact, only with the guards. They do not

receive phone privileges or any other privileges that will allow them to contact other people

including their family. Inmates often resort to trying to communicate to each other through the

walls and vents of their cells. The contact that the inmates have with guards is at a minimum.

The guards walk the inmates from the cell to the shower or yards and back to their cells. When it

is time for the inmates to eat, they are fed through a small slot in the door of their cell ​(Casella &

Ridgeway, n.d.). Inmates within the system emotions grow with fury, and they are unable to

withstand the system without mental effects.

Hunger Strike
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Conditions at Pelican Bay cause varying effects within inmates. On July seventh 2013 the

inmates reached the point of exhaustion, and they were tired of being treated like nothing. On

July eighth a hunger strike led by an inmate known as Ashker began within the walls of the

Pelican Bay Prison​ (Wallace-Wells, 2014)​. The strike was intended to end long term

incarceration in solitary confinement.The strike spread like wildfire throughout the prison.

Within the first day 30,000 prisoners statewide had joined the strike ​(NPR, 2014)​. The hunger

strike lasted for 31 days​ (Murillo, 2013)​. As the strike lasted, the number of participants had

lowered from 30,000 to about 11,000. The strike took a variety of tolls on prisoners. These tolls

ranged from fatigue to an increase in energy and clarity within their conversations. Those who

participated in the strike were moved to a separate cell area where they could be watched. This

move symbolised progression for the strike. The prisoners who had been locked away for years

were finally able to exercise outside and experience fresh air. As the days went on, the support

grew weak for the hunger strike; however, with the hunger strikes Ashker and other inmates

were allowed to speak with attorneys on the matter ​(Wallace-Wells, 2014). They were fighting

for better conditions within the SHU and better treatment. The inmates asked to at least have the

ability to make weekly phone calls to their families and to have the ability to write and send

photos to their family as well ​(Murillo, 2013). ​ The inmates ended the strike, and there were few

to no gains from the strike. Towards the end, the strike leaders decided to end the strike in order

for the health of other protesters. The strike did not end because their demands were met, but

because of the health of other inmates. Although the strike ended, its leaders still withhold a

passion to correct the treatment of prisoners within the system ​(John, 2013)​.

Lawsuits
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The Pelican Bay Prison System has faced several lawsuits concerning their solitary

confinement policies and how they treat inmates within the SHU.​ ​The lawsuit against Pelican

Bay is known as​ Ashker v. Governor of California​. The lawsuit came about as a grievance from

several prisoners. The lawsuit claims 500 inmates had been held in the SHU for at last ten years,

and that 78 had been in the SHU for more than 20 years. The inmates involved in the suit had

crime history that varied from serious offenses landing them in solitary confinement or simply

being placed in solitary confinement because of alleged gang affiliation within the jail walls. The

inmates were stripped of all senses of freedom and treated as though they meant nothing. The

inmates were able to present to the court that solitary confinement put them in “grave risk” of

mental defects. The professor of psychology that helped the inmates prove this point is Craig

Haney. Mr. Haney was able to show through interviews the effect that solitary confinement was

taking on the inmates. He discovered that the effects on prisoners ranged from intrusive thoughts

to difficulties with memory, and some even suffered from “extreme forms of psychopathology

-hallucinations.” As a result of the lawsuit the prison and the inmates were able to reach a

settlement, and the lead attorney for the inmates , Jules Lobel, is hopeful that the chang reached

in Pelican Bay will spread out to all other prisons within California and the United States. The

settlement states that inmates can not be sent to the SHU based on the assumption of gang

affiliation, but they must first be found guilty at a hearing. If the inmates are found guilty at the

hearing their stay in solitary confinement must be defined, and not left to an indeterminate

sentence. The settlement also establishes that the prison will build a new unit for those who

violate prison rules but do not fit into the category of solitary confinement. It also allows for the

courts to review the cases of all prisoners in solitary confinement because of gang affiliation and
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determine if they may be released into the general population. As a result of this settlement,

many inmates who have been in solitary for more than 10 years are looking at being released

(Mccarthy, 2015)​.

Laws on Solitary Confinement

When it comes to solitary confinement, many states and cities struggle with creating laws

and regulations for the use. Virginia does not have a state wide established set of laws for the use

and regulations of solitary confinement. It is up to each city jail to determine the rules and

regulations concerning their isolation units. The lack of governing laws from states is part of the

reason that the conditions within isolation vary as widely as they do. Having state guidelines

could possibly reduce many of the issues with isolation. Allowing the prisons to establish their

own rules causes conditions to be inhuman and detrimental to the prisoners. A unified form of

isolation statewide would allow easier control over what happens with isolation.

Chesapeake Regulations

After conducting an interview with Kenneth Mayo, a Chesapeake officer who works

within the Chesapeake jail, states the guidelines for isolation within their prison. Within isolation

at the Chesapeake jail the inmates are on a 23 hour rotation. They are in their room for 23 hours

out of the day. They are released from their cell in order to shower and exercise. They are

restricted of television privileges. Access to the phone is restricted to phone calls to their legal

counsel. Mr. Mayo works with isolation on a daily basis and he states that prisoners have

complete personality changes from being in isolation. He states that, “One day they go in as a

mentally stable and normal person and after a few days they come out not knowing the day or

time,” he disagrees with the use of isolation in some ways because of what he sees. The jail has a
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30 day maximum rule. This rule allows for an inmate to only be held in confinement for no more

than 30 days. Mr. Mayo believes there should be some reforms made to the regulations at his

prison, but he does not believe that the unit should be done away with completely ​(K. Mayo,

Personal communication, November 2, 2017) .​ The interview provides insight from prison

guards who believe themselves after seeing first hand the effects that the guidelines need to be

reformed.

US to Other Countries

Looking at the issue compared to other countries the United States falls somewhere in the

middle when it comes to the level of severity. Many countries strongly enforce their solitary

units and host conditions far worse than the United States. While others either do not use

isolation units or their units are more laxed. In Canada the government has rejected the request to

reduce or limit solitary confinement in federal prisons. Which would, therefore, limit the stay in

isolation to 15 days at a a time and no more than 60 days in a year. The government believes that

a change would put the guards at risk along with prisoners. One in six inmates within the

Canadian isolation unit will spend over 120 days in isolation. In 1933 the Canadian prisons

restricted the stay in isolation for disciplinary actions to no more than 3 days. Since then many

prison systems have gone around or broken that rule. In Germany the statue allows the use of

isolation with a maximum of three months a year. Even then the isolation must be deemed

completely necessary. In Great Britain they rely on the prison administrators to determine the use

and extent of solitary confinement. With this regulation set in place, the prisons in Britain rarely

use their isolation units. France has a set of laws in place where the use of isolation must be

reviewed prior to placing the inmate and 30 days after the inmate has been in confinement.
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However, many prisons ignore these rules and use isolation how they see fit. Other countries like

Japan and China have a specific set of restrictions on their isolation units, but their conditions are

worse than those in the American system ​(Lippold, 2015) ​. American systems vary across the

nation. Each state follows a different set of rules. Within those states the prisons also follow

another set of rules. Countries like the ones mentioned before have a somewhat uniform set of

laws but many of their isolation units are worse than those in America. The United States should

follow the examples of some of these countries by setting a general rule of law for states and

restricting the amount of days an inmate may be held in isolation nationwide.

Case Law

In the case of ​Hutto v. Finney​ the question that came before the court was “ Did punitive

isolation for more than thirty days in the Arkansas prison system constitute cruel and unusual

punishment as prohibited by the Eighth and Fourteenth Amendments?” After observing the diet

and living conditions of inmates in isolation a District Court labeled the conditions as “a dark

and evil world completely alien to the free world,”the court had even noticed that some of the

prison guards were inmates who had been issued guns. This case took place in 1969 in an

Arkansas prison. It challenged the idea of isolation with the prison. In this prison isolation was

done for unknown periods of time in windowless over crowded cells ​("Hutto v. Finney," 1978).

The conditions within this prison were at an extreme. The inmates were only given a toilet which

only flushed from the outside and fewer than 1,000 calories a day. The courts ruled that the

conditions were harsh enough to classify isolation as a form of punishment which led to the use

being able to violate eighth amendment standards. Furthermore, an injunction requiring the diet

the prisoners were on be taken away and the living conditions with the inmates cells be
SOLITARY CONFINEMENT 14

improved. Along with these things the sentence to isolation could not exceed 30 days

consecutively.

Juveniles

Adult are not the only ones who are affected by this from of prison punishment. Juveniles

held in adult and juvenile facilities are subject to solitary confinement and its effects as well.

According to an article written by Eli Hager on juvenile solitary confinement, 23% of juvenile

facilities practice isolation ​(Hager, 2017)​. The effects of solitary confinement are stronger on

teenagers. Juveniles may be placed in isolation under many of the same conditions as adults.

Some of these conditions include disciplinary actions and protective reasoning. Currently there

are approximately 70,00 juveniles in jail and more than a third of them have experienced

isolation. These effects cause them to have long lasting effects that still taunt them after they are

released​ (Dimon, 2014)​.

Effects

A former inmate from a juvenile facility is still being affected from being placed in

solitary confinement 16 years later (Dimon, 2014). During the time a juvenile is placed in a

facility their brains are still developing and learning how to adapt and how things should be.

Being placed in confinement during this stage causes the brain to experience severe changes. The

major area of the brain that controls the main cognitive points is being affected the most (Dimon,

2014). Solitary confinement increases the likelihood of suicide within a juvenile facility. The

Attorney General’s National Task Force on Children Exposed to Violence have found that half

the amount of suicides within a juvenile facility can be directly related to isolation (Dimon,

2014). Former inmates have reported that even after being released they still experience paranoia
SOLITARY CONFINEMENT 15

and irrational thoughts. Isolation has caused its victims to lose self esteem that they can not gain

back. In a documentary put together by​ Human RIghts Watch,​ former teenage isolation inmates

tell their story about being in isolation at such a young age. Many describe the experience of

solitary confinement as being alone and worthless. Some inmates tell what they did in order to

try and stay sane.​ These things include drawing on the walls with body fluids. One inmate

describes isolation as making him violent. He wanted to kill himself and others. The inmates

formerly subjected to isolation at a young age say that there is no rehabilitation for the things

they experience in isolation. Doctors within the documentary state that the use should be banned

because of how it stops or depletes the cognitive development ​(Human Rights Watch, director,

2012)​. Solitary Confinement has not proven to be effective as much as it has been proven to be

ineffective in teens. Because of these findings it has caused several authorities to push for

reforms on the usage.

Victims of Juvenile Isolation

Isolation in youth has proved to be dangerous both in studies and through real examples.

Isolation changes the ways that the youth view things and themselves. Many youth fall victim to

the harmful effects of isolation on the daily. Kalief Browder, a 16 year old male, had been sent to

Rikers Island for a theft charge in which he denied partaking in. Kalief’s case was up for review

for three years, and out of those three years, he spent two within an isolation cell. His case was

dismissed in 2015 and he was able to go home. While he was free from the isolation cell, his

brain was not. Soon after being released Kalief took his own life at his home. Being put away

from people for an extended period took a toll on his mind. Upon being released, he no longer

knew how to handle society and the outside life. Which then led him to taking his own life
SOLITARY CONFINEMENT 16

(Hager,2017). Along with Kalief, there are other victims of juvenile isolation. Isolation takes

over the minds of juveniles and causes them to lose sight of life and lose all hope. Not all victims

take their lives, but some live with the damaging mental effects and struggled to fit in with

society.

Reforms on Juvenile Usage

With the topic of isolation being so heavy in the news, many states have begun taking

steps to end or reduce the usage. In 2016 former President Obama began to take the steps to end

juvenile isolation of a federal scale by ending the use in all federal facilities. Following this

proceeding many states such as Wisconsin, Tennessee, New York, California, and others have

begun to eliminate the extended use of confinement for juveniles. These reforms are showing

sign of a possible national banning on the issue of long term confinement in youth. After further

looking into the situations more states are agreeing on the issue that the use of isolation is

unconstitutional to youth. Because of this belief, many states like Wisconsin are moving to set

specific guidelines on the usage. In Wisconsin youth may not be held for more than 7 days and

they must be allocated at least 30 hours outside of their cell in a week. Before these regulations,

they could be held for longer than 60 days. Along with the new regulations, the inmates must be

provided with education, therapy, and other essentials ​(Hager, 2017). Following this movement,

other states like California, Colorado, North Carolina, and Connecticut have also changed their

policies and guidelines for juvenile isolation (Hager,2017). The new reforms coming within

different state and federal facilities are beginning to show a decrease in the use of isolation for

youth with jails. Although many states are changing their policies many states are remaining

stagnant in their position and have yet to make a move on the issue of children in isolation.
SOLITARY CONFINEMENT 17

Upcoming Reforms

While reforms are slowly coming, they are receiving more backlash than support. People

are beginning to slowly get to onboard with the idea of banning or limiting the use of solitary

confinement. Many organizations like the AFSC, the American Friends Service Committee, have

began to push the efforts against solitary confinement ​(American Friends Service Committee,

2017)​. In 2014 the AFSC submitted a report documenting testimonies of previous isolation

inmates to the U.N. Committee Against Torture. The organization is one of the view constantly

active organizations combating the issue of solitary confinement. Several politicians have spoken

out against the use of isolation. Supreme Court Justice Anthony Kennedy and Pope Francis have

spoken against the use of long term confinement. Even former President Barack Obama made

effort to reduce or ban the use of isolation within federal facilities. While he was in office

President Obama “asked Attorney General Loretta Lynch to “start a review of the overuse of

solitary confinement across American prisons,”​(Casella & Zehr, 2015)​. The idea that although

people make mistakes to put them in prison, they are still people and still deserve to be treated as

so is also being heavily induced by former President Barack Obama. Eric Holder, former

Attorney General, has also criticized the use of isolation twice over the past years. The situation

has taken such measures that the US Senate has called for reforms from the U.S. Bureau of

Prisons ​(Casella & Zehr, 2015). The Association of State Correctional Administrators (ASCA)

has created a practice where the isolation setting is less restrictive and the prisons must be able to

justify the placement of inmates in isolation along with other reforms ​("FACT SHEET:

Department of Justice Review of Solitary Confinement," 2016). ​The Bureau of Prisons has
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reduced its isolation usage by about 25% by imposing new regulations. Following this example,

President Barack Obama has adopted some of these regulations. These regulations include end of

isolation for juveniles, sending mentally ill patients to facilities that can care for them, and

expanding out of cell time ("FACT SHEET: Department of Justice Review of Solitary

Confinement," 2016). These regulations have been imposed as an effort to better the conditions

in isolation beginning with federal jails with hopes of expanding into state facilities.

Conclusion

Solitary Confinement is a legal form of inhumane torture that needs to be reformed if it

can not be done away with completely. Isolation takes a detrimental effect on prisoners while

they are in their cells and continues to haunt them when they are released. The psychological

effects are beyond repair while the victims of this torture cry out for help. From the

hallucinations to the loss of hope and the will to live, solitary confinement has proved itself to be

more harmful than it is helpful. Many leading figures and organizations across the nation have

begun to make efforts to help the victims of this torture. While efforts are being made, there are

still people suffering inside these walls of isolation. In conclusion, solitary confinement does

more harm to the prisoners and the community surrounding its victims than good. While

prisoners do need some form of correction when they disobey prison rules, isolation is not the

correct way. Reforming the guidelines in isolation or implementing a statewide code for isolation

are steps in the right direction towards helping the victims of solitary confinement. While

prisoners have committed crimes to put them in jail, they still deserve to be treated as humans.
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American Friends Service Committee. (2017, March 20). Solitary confinement. Retrieved from

https://www.afsc.org/key-issues/issue/solitary-confinement
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Ashker v. Governor of California. (2012, May 31). Retrieved September 25, 2017, from

https://ccrjustice.org/home/what-we-do/our-cases/ashker-v-brown

Board, T. E. (2017, August 05). Pulling Back on the Barbaric Use of Solitary Confinement.

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Casella, J., & Ridgeway, J. (2016, February 11). A Brief History of Solitary Confinement.

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Castillo, L. C. (2015, March). No Child Left Alone: Why Iowa Should Ban Juvenile Solitary

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Dimon, L. (2014, June 30). How Solitary Confinement Hurts the Teenage Brain. Retrieved from

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Durbin: First-Of-Its-Kind Report On Solitary Confinement Shows Need For More Improvement

| U.S. Senator Dick Durbin of Illinois. (2015, February 27). Retrieved from

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