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Mental Health Issues in Long-Term Solitary and "Supermax" Confinement, Craig Haney, 2003

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Mental Health Issues in Long-Term
Solitary and "Supermax" Confinement
Craig Haney
This article discusses the recent increase in the use of solitary-like confinemem, especially the rise of so-called supermax prisons and the special mental health issues and
challenges they pose. After briefly discussing the natllre ofthese specialized and increasingly widespread units and the forces that have given rise to them, the article reviews
some of the unique mental-health-related issues they present, including the large literature that exists on the negative psychological effects of isolation and the unusually high
percemage of mentally ill prisoners who are confined there. It ends with a brief discussion of recent caselaw that addresses some of these memal health issues and suggests
that the cmtrts, though in some ways appropriately solicitous of the plight ofmentally ill
supermax prisoners, have overlooked some of the broader psychological problems these
units create.
Keywords: srtpermax; solitary confinemellt; effects of imprisonment

The field of corrections is arguably impervious to much truly significant change. Of all of the institutions in our society, prisons retain the greatest
similarity to their early 19th century form. Indeed, until relatively recently,
more than a few prisoners were housed in facilities that had been constructed
a half century or more ago. Althollgh there have been advances in the methods by which correctional regimes approach the task of changing or rehabilitating prisoners, and a number ofimprovementsmade in overall conditions of
confinement compared to the 19th century (often brought about by litigation
compelling prison systems to modernize and improve), many of the basic
facts of prison life have remained relatively constant. Notwithstanding
increased sophistication in the technology of incarcerative social control, and
the waxing and waning in popularity of one or another kind of prison treatment program, the argument that there has been nothing fundamentally new
on the correctional landscape for many years would be difficult to refute.
However, in this article, I suggest that the last decade of the 20th century did see the rise of a new penal form-the so-called supermax prison.
Increasing numbers of prisoners now are being housed in a new form of
CRAIG HANEY: University of California, Santa Cruz.
CRIME & DELINQUENCY. Vol. 49 No. I, January 2003 124-156
DOl: 10.1177/0011128702239239
© 2003 Sage Publications




solitary or isolated confinement that, although it resembles the kind of
punitive segregation that has been in use since the inception of the prison,
has a number of unique features. 1 At the start of the 1990s, Human Rights
Watch (1991) identified the rise of supermax prisons as "perhaps the most
troubling" human rights trend in U.S. corrections and estimated that some 36
states either had completed or were in the process of creating some kind of
"super maximum" prison facility. By the end of the decade, the same organization estimated that there were approximately 20,000 prisoners confined to
supermax-type units in the United States (Human Rights Watch, 2000) and
expressed even more pointed concerns about their human rights implications.
Because most experts agree that the use of such units has increased significantly since then, it is likely that the number of persons currently housed in
supermax prisons is considerably higher.
There are few if any forms of imprisonment that appear to produce so
much psychological trauma and in which so many symptoms of psychopathology are manifested. Thus, the mental health implications of these units
are potentially very significant. Despite the slight (and sometimes not so
slight) variations in the ways different state prison systems approach this
most restrictive form of confinement, supermax prisons have enough in common to permit some generalizations about what they are, why they have come
about, what special mental health issues they raise, and how they might be
regulated and reformed to minimize some of the special risks they pose. I will
try to address each of these issues in turn in the pages that follow.


Supermax confinement represents a significant variation in the longstanding practice of placing prisoners in what is known as solitary confinement or punitive segregation. For practical as well as humanitarian reasons,
prisoners have rarely been confined in literal or complete solitary confinement? But prisoners in solitary or isolation have always been physically segregated from the rest of the prison population and typically excluded from
much of the normal programming, routines, opportunities, and collective
activities available in the mainline institution. By the late 19th century, most
jurisdictions in the United States had, for the most part, restricted solitary
confinement to relatively brief periods of punishment that were imposed in
response to specified infractions of prison rules. 3
In contrast to this traditional form of isolation, supermax differs in several
important ways-primarily the totality of the isolation, the intended duration
of the confinement, the reasons for which it is imposed, and the technological



sophistication with which it is achieved. In particular, supermax prisons
house prisoners in virtual isolation and subject them to almost complete idleness for extremely long periods of time. Supermax prisoners rarely leave
their cells. In most such units, an hour a day of out-of-cell time is the norm.
They eat all of their meals alone in the cells, and typically no group or social
activity of any kind is permitted. 4
When prisoners in these units are escorted outside their cells or beyond
their housing units, they typically are first placed in restraints-chained
while still inside their cells (through a food port or tray slot on the cell
door)-and sometimes tethered to a leash that is held by an escort officer.
They are rarely if ever in the presence of another person (including physicians and psychotherapists) without being in multiple forms of physical
restraints (e.g., ankle chains, belly or waist chains, handcuffs). Supermax
prisoners often incur severe restrictions on the nature and amounts of personal property they may possess and on their access to the prison library, legal
materials, and canteen. Their brief periods of outdoor exercise or so-called
yard time typically take place in caged-in or cement-walled areas that are so
constraining they are often referred to as "dog runs." In some units, prisoners
get no more than a glimpse of overhead sky or whatever terrain can be seen
through the tight security screens that surround their exercise pens.
Supermax prisoners are often monitored by camera and converse through
intercoms rather than through direct contact with correctional officers. In
newer facilities, computerized locking and tracking systems allow their
movement to be regulated with a minimum of human interaction (or none at
all). Some supermax units conduct visits through videoconferencing equipment rather than in person; there is no immediate face-to-face interaction (let
alone physical contact), even with loved ones who may have traveled great
distances to see them. In addition to "video visits," some facilities employ
"tele-medicine" and "tele-psychiatry" procedures in which prisoners' medical and psychological needs are addressed by staff members who "examine"
them and "interact" with them over television screens from locations many
miles away.
Supermax prisons routinely keep prisoners in this near-total isolation and
restraint for periods of time that, until recently, were unprecedented in modern corrections. Unlike more traditional forms of solitary confinement in
which prisoners typically are isolated for relatively brief periods of time as
punishment for specific disciplinary infractions, supermax prisoners may be
kept under these conditions for years on end. Indeed, many correctional systems impose supermax confinement as part of a long-term strategy of correctional management and control rather than as an immediate sanction for discrete rule violations.



In fact, many prisoners are placed in supermax not specifically for what
they have done but rather on the basis of who someone in authority has judged
them to be (e.g., "dangerous," "a threat," or a member of a "disruptive"
group). In many states, the majority of supermax prisoners have been given
so-called indeterminate terms, usually on the basis of having been officially
labeled by prison officials as gang members. An indeterminate supermax
term often means that these prisoners will serve their entire prison term in isolation (unless they debrief by providing incriminating information about
other alleged gang members). 5 Prisoners in these units may complete their
prison sentence while still confined in supermax and be released directly
back into the community. If and when they are returned to prison on a parole
violation or subsequent conviction, they are likely to be sent immediately
back to supermax because of their previous status as a supermax prisoner.
To summarize: prisoners in these units live almost entirely within the confines of a 60- to 80-square-foot cell, can exist for many years separated from
the natural world around them and removed from the natural rhythms of
social life, are denied access to vocational or educational training programs
or other meaningful activities in which to engage, get out of their cells no
more than a few hours a week, are under virtually constant surveillance and
monitoring, are rarely if ever in the presence of another person without being
heavily chained and restrained, have no opportunities for normal conversation or social interaction, and are denied the opportunity to ever touch another
human being with affection or caring or to receive such affection or caring
themselves. Because supermax units typically meld sophisticated modem
technology with the age-old practice of solitary confinement, prisoners experience levels of isolation and behavioral control that are more total and complete and literally dehumanized than has been possible in the past. The combination of these factors is what makes this extraordinary and extreme form
of imprisonment unique in the modem history of corrections. Its emergence
in a society that prides itself on abiding "evolving standards of decency"
(Trop v. Dulles, 1958) to regulate its systems of punishment requires some


Two important trends in modem American corrections help to account for
the creation of this new penal form. The first is the unprecedented growth in
the prison population that started in the mid-1970s and continued into the
early years of the 21st century. The rate of incarceration in the United States
(adjusting for any increases in overall population) remained stable over the



50-year period from 1925 to 1975. Remarkably, it then quintupled over the
next 25-year period. Most state prison systems doubled in size and then doubled again during this period, with no commensurate increase in the
resources devoted to corrections in general or to programming and mental
health services in particular (Haney & Zimbardo, 1998).
This dramatic influx of prisoners-and the overcrowding crisis it produced-occurred at approximately the same time that another important
change was underway. In the mid-1970s, the United States formally abandoned its commitment to the rehabilitative ideals that had guided its prison
policy for decades. Often at the insistence of the politicians who funded their
prison systems, correctional administrators embraced a new philosophy built
on the notion that incarceration was intended to inflict punishment and little
else. The mandate to provide educational, vocational, and therapeutic programming in the name of rehabilitation ended at an especially inopportune
time (Haney, 1997). Prisons throughout the country were filled to capacity
and beyond, and the prisoners who were crowded inside had few opportunities to engage in productive activities or to receive help for preexisting psychological or other problems.
Under these conditions of unprecedented overcrowding and unheard of
levels of idleness, prison administrators lacked positive incentives to manage
the inevitable tensions and conflicts that festered behind the walls. In systems
whose raison d'etre was punishment, it was not surprising that correctional
officials turned to punitive mechanisms in the hope of buttressing increasingly tenuous institutional controls. Of course, disciplinary infractions often
were met with increasing levels of punishment in the modern American
prison, even before these trends were set in motion. But the magnitude of
the problem faced by correctional administrators in the 1980s pushed
their response to an unprecedented level. Supermax prisons emerged in this
context-seized on as a technologically enhanced tightening screw on the
pressure cooker-like atmosphere that had been created inside many prison
systems in the United States. As the pressure from overcrowding and idleness
increased, the screw was turned ever tighter.
Historically, correctional polices often harden in times of prison crisis.
But once the problem causing the increased tension or turmoil has been identified and resolved, the punitive response typically de-escalates, sometimes
leading to even more hospitable conditions and treatment. Unfortunately, the
prison overcrowding problem did not subside during the 1980s and 1990s,
and the continued punitive atmosphere that marked this period meant that
corrections officials were in no position look "soft" in the face of the crisis.



The politics of the era deprived prison administrators of alternative
approaches and guaranteed a one-way ratcheting up of punishment in the
face of these tensions. They became increasingly committed to more forcibly
subduing prisoners whose behavior was problematic ("a threat to the safety
and security of the institution"), taking fewer chances with others whom they
suspected might be a problem, and set about intimidating everyone else who
might be thinking about causing disruption. Supermax simultaneously provided politicians with another stark symbol to confirm their commitment to
tough-on-crime policies (Riveland, 1999) and gave prison officials a way of
making essentially the same statement behind the walls.
I belabor this recent correctional history to debunk several myths that surround the rise of the supermax prison form. This new kind of prison did not
originate as a necessary or inevitable response or backlash to some sort of
"permissive" correctional atmosphere that allegedly prevailed in the 1960s,
as some who defend the recent punitive trends in imprisonment have suggested (cf. O'Brien & Jones, 1999). It was not a badly needed corrective to
liberal prison policies or to previous capitulations to the prisoners' rights
movement. Quite the opposite. Supermaxes began in response to the overcrowded and punitive 1980s and came into fruition in the even more overcrowded and more punitive 1990s. They are in many ways the logical extension of a system founded on the narrow premise that the only appropriate
response to misbehavior is increased punishment.
In addition, there is no evidence that the rise of supermax prisons was
driven by the threat of some new breed of criminal or prisoner. The natural
human tendency to individualize, dispositionalize, and sometimes even to
demonize problematic behavior, and to ignore the contextual forces that help
create it, is intensified in prison systems as perhaps nowhere else. Thus, when
correctional officials faced unprecedented pressures from dramatically
increased levels of overcrowding and idleness, they naturally ignored the
contextual origins of the problem (over which they had little or no control)
and blamed the prisoners (over which they did).
But, even if supermax prisons now contain only "the worst of the
worst"6-a phrase that is often used to justify the use of these newly designed
units but whose accuracy is hotly disputed by their critics-there is no evidence that these allegedly "worst" prisoners are any worse than those who
had been adequately managed by less drastic measures in the past. In assessing the benefits and burdens of supermax confinement, it is important to keep
in mind that correctional officials have not been given a mandate to engage in
such extraordinarily punitive and unprecedented measures because they now



confront not only an extraordinarily dangerous but new strain of prisoner that
has never before existed. There is no such new breed and no such mandate.

In assessing the mental health concerns raised by supermax prisons, it is
important to acknowledge an extensive empirical literature that clearly establishes their potential to inflict psychological pain and emotional damage.
Empirical research on solitary and supermax-like confinement has consistently and unequivocally documented the harmful consequences of living in
these kinds of environments. Despite some methodological limitations that
apply to some of the individual studies, the findings are robust. Evidence of
these negative psychological effects comes from personal accounts, descriptive studies, and systematic research on solitary and supermax-type confinement, conducted over a period of four decades, by researchers from several
different continents who had diverse backgrounds and a wide range of professional expertise. Even if one sets aside the corroborating data that come
from studies of psychologically analogous settings-research on the harmful effects of acute sensory deprivation (e.g., Hocking, 1970; Leiderman,
1962), the psychological distress and other problems that are created by the
loss of social contact such as studies of the pains of isolated, restricted living in the free world (e.g., Chappell & Badger, 1989; Cooke & Goldstein,
1989; Harrison, Clearwater, & McKay, 1989; Rathbone-McCuan &
Hashimi, 1982), or the well-documented psychiatric risks of seclusion for
mental patients (e.g., Fisher, 1994; Mason, 1993)-the harmful psychological consequences of solitary and supermax-type confinement are extremely
well documented.
Specifically, in case studies and personal accounts provided by mental
health and correctional staff who worked in supermax units, a range of similar adverse symptoms have been observed to occur in prisoners, including
appetite and sleep disturbances, anxiety, panic, rage, loss of control, paranoia, hallucinations, and self-mutilations (e.g., Jackson, 1983; Porporino,
1986; Rundle, 1973; Scott, 1969; Slater, 1986). Moreover, direct studies of
prison isolation have documented an extremely broad range of harmful psychological reactions. These effects include increases in the following potentially damaging symptoms and problematic behaviors: negative attitudes and
affect (e.g., Bauer, Priebe, Haring, & Adamczak, 1993; Hilliard, 1976; Koch,
1986; Kom, 1988a, 1988b; Miller & Young, 1997; Suedfeld, Ramirez,
Deaton, & Baker-Brown, 1982), insomnia (e.g., Bauer et al., 1993; Brodsky &



Scogin, 1988; Haney, 1993; Koch, 1986; Korn, 1988a, 1988b), anxiety (e.g.,
Andersen et al., 2000; Brodsky & Scogin, 1988; Grassian, 1983; Haney,
1993; Hilliard, 1976; Koch, 1986; Korn, 1988a, 1988b; Tach, 1975; Volkart,
Dittrich, Rothenfluh, & Werner, 1983; Walters, Callagan, & Newman, 1963),
panic (e.g., Tach, 1975), withdrawal (e.g., Cormier & Williams, 1966;
Haney, 1993; Miller & Young, 1997; Scott & Gendreau, 1969; Tach, 1975;
Waligora, 1974), hypersensitivity (e.g., Grassian, 1983; Haney, 1993;
Volkart, Dittrich, et al., 1983), ruminations (e.g., Brodsky & Scogin, 1988;
Haney, 1993; Korn, 1988a, 1988b; Miller & Young, 1997), cognitive dysfunction (e.g., Brodsky & Scogin, 1988; Grassian, 1983; Haney, 1993; Koch,
1986; Korn, 1988a, 1988b; Miller & Young, 1997; Suedfeld & Roy, 1975;
Volkart, Dittrich, et al., 1983), hallucinations (e.g., Brodsky & Scogin, 1988;
Grassian, 1983; Haney, 1993; Koch, 1986; Korn, 1988a, 1988b; Suedfeld &
Roy, 1975), loss of control (e.g., Grassian, 1983; Haney, 1993; Suedfeld &
Roy, 1975; Tach, 1975), irritability, aggression, and rage (e.g., Bauer et al.,
1993; Brodsky & Scogin, 1988; Cormier & Williams, 1966; Grassian, 1983;
Haney, 1993; Hilliard, 1976; Koch, 1986; Miller & Young, 1997; Suedfeld et
al., 1982; Tach, 1975), paranoia (e.g., Cormier & Williams, 1969; Grassian,
1983; Volkart, Dittrich, et al., 1983), hopelessness (e.g., Haney, 1993;
Hilliard, 1976), lethargy (e.g., Brodsky & Scogin, 1988; Haney, 1993; Koch,
1986; Scott & Gendreau, 1969; Suedfeld and Roy, 1975), depression (e.g.,
Andersen et al., 2000; Brodsky & Scogin, 1988; Haney, 1993; Hilliard, 1976;
Korn, 1988a, 1988b), a sense of impending emotional breakdown (e.g.,
Brodsky & Scogin, 1988; Grassian, 1983; Haney, 1993; Koch, 1986; Korn,
1988a, 1988b; Tach, 1975), self-mutilation (e.g., Benjamin & Lux, 1975;
Grassian, 1983; Toch, 1975), and suicidal ideation and behavior (e.g.,
Benjamin & Lux, 1975; Cormier & Williams, 1966; Grassian, 1983; Haney,
In addition, among the correlational studies of the relationship between
housing type and various incident reports, again, self-mutilation and suicide
are more prevalent in isolated housing (e.g., Hayes, 1989; Johnson, 1973;
A. Jones, 1986; Porporino, 1986), as are deteriorating mental and physical
health (beyond self-injury), other-directed violence, such as stabbings,
attacks on staff, and property destruction, and collective violence (e.g.,
Bidna, 1975; Edwards, 1988; Kratcoski, 1988; Porporino, 1986; Sestoft,
Andersen, Lilleback, & Gabrielsen, 1998; Steinke, 1991; Vol kart,
Rothenfluh, Kobelt, Dittrich, & Ernst, 1983). The use of extreme forms of
solitary confinement in so-called brainwashing and torture also underscores
its painful, damaging potential (e.g., Deaton, Burge, Richlin, & Latrownik,
1977; Foster, 1987; Hinkle & Wolff, 1956; Riekert, 1985; Shallice, 1974;
Vrca, Bozikov, Brzovic, Fuchs, & Malinar, 1996; West, 1985). In fact, many



of the negative effects of solitary confinement are analogous to the acute
reactions suffered by torture and trauma victims, including post-traumatic
stress disorder or PTSD (e.g., Herman, 1992, 1995; Horowitz, 1990;
Hougen, 1988; Siegel, 1984) and the kind of psychiatric sequelae that plague
victims of what are called "deprivation and constraint" torture techniques
(e.g., Somnier & Genefke, 1986).
To summarize, there is not a single published study of solitary or
supermax-like confinement in which nonvoluntary confinement lasting for
longer than 10 days, where participants were unable to terminate their isolation at will, that failed to result in negative psychological effects. The damaging effects ranged in severity and included such clinically significant symptoms as hypertension, uncontrollable anger, hallucinations, emotional
breakdowns, chronic depression, and suicidal thoughts and behavior. Of
course, it is important to emphasize that not all supermax prisons are created
equal, and not all of them have the same capacity to produce the same number
and degree of negative psychological effects. Research on the effects of
social contexts and situations in general and institutional settings in particular underscores the way in which specific conditions of confinement do matter. Thus, there is every reason to expect that better-run and relatively more
benign supermax prisons will produce comparatively fewer of the preceding
negative psychological effects, and the worse run facilities will produce comparatively more.


In addition to the serious nature and wide range of adverse symptoms that
have been repeatedly reported in a large number of empirical studies, it is
important to estimate their prevalence rates-that is, the extent to which prisoners who are confined in supermax-type conditions suffer its adverse
effects. My own research at California's Pelican Bay "security housing unit"
(or SHU)-a prototypical supermax prison at the time these data were collected-provides one such estimate. In this section, I describe this research in
some detail and situate its findings by comparing them to prevalence rates
among several other relevant groups.
In the Pelican Bay study, each prisoner was individually assessed in faceto-face interviews. Because the sample of 100 SHU prisoners was randomly
selected, the data are representative of and, within appropriate margins of
error, generalizable to the entire group of prisoners at this supermax facility. 7
The following two important areas were explored in each interview. In the



TABLE 1: Symptoms of Psychological and Emotional Trauma

Anxiety, nervousness
Lethargy, chronic tiredness
Trouble sleeping
Impending nervous breakdown
Perspiring hands
Heart palpitations
Loss of appetite
Hands trembling
Tingling sensationa

% Presence Among Pelican Bay SHU Prisoners


NOTE: SHU = security housing unit.
a. Not necessarily a symptom of psychological trauma. It is included as a control question to provide a baseline against which to measure the significance of the traumarelated responses.

first, one series of questions focused on whether the prisoner experienced any
of 12 specific indices of psychological trauma or distress. A list of those
symptoms regarded as reliable indicators of general psychological distress
was employed. They were essentially the same indices of distress that Jones
(1976) and others have used to assess mainline prison populations. In the second, a different series of questions was designed to determine whether the prisoner suffered any of 13 specific psychopathological effects of isolation. Based
on previous research conducted by Grassian (1983) and others (e.g.,
Brodsky & Scogin, 1988; Korn, 1988a, 1988b), a list of isolation-related
symptoms was developed and used to assess each prisoner in this regard.
The results of this prevalence study are depicted in Tables 1 and 2. As
Table 1 indicates, every symptom of psychological distress but one (fainting
spells) was suffered by more than half of the representative sample of
. supermax prisoners. Two thirds or more of the prisoners reported being bothered by many of these symptoms in the SHU, and some were suffered by
nearly everyone. For example, virtually all of the isolated prisoners were
plagued by nervousness and anxiety, by chronic lethargy, and a very high percentage (70%) felt themselves on the verge of an emotional breakdown. In
addition, a very high number suffered from headaches and troubled sleep,
and more than half were bothered by nightmares. Well over half of the
supermax prisoners reported a constellation of symptoms-headaches, trembling, sweaty palms, and heart palpitations-that is commonly associated
with hypertension.



TABLE 2: Psychopathological Effects of Prolonged Isolation

% Presence Among Pelican Bay SHU Prisoners

Irrational anger
Oversensitivity to stimuli
Confused thought process
Social withdrawal
Chronic depression
Emotional flatness
Mood, emotional swings
Overall deterioration
Talking to self
Violent fantasies
Perceptual distortions
Suicidal thoughts


NOTE: SHU = security housing unit.

As Table 2 shows, the psychopathological symptoms of isolation were
even more prevalent among these prisoners. Almost all of the supermax prisoners reported suffering from ruminations or intrusive thoughts, an
oversensitivity to external stimuli, irrational anger and irritability, confused
thought processes, difficulties with attention and often with memory, and a
tendency to withdraw socially to become introspective and avoid social contact An only slightly lower percentage of prisoners reported a constellation
of symptoms that appeared to be related to developing mood or emotional
disorders--concerns over emotional flatness or losing the ability to feel,
swings in emotional responding, and feelings of depression or sadness that
did not go away. Finally, sizable minorities of supermax prisoners reported
symptoms that are typically only associated with more extreme forms of
psychopathology-hallucinations, perceptual distortions, and thoughts of
To put both sets of figures in perspective, it is possible to compare these
prevalence rates with those derived from other populations in which similar
assessments have been made. For example, Dupuy, Engel, Devine, Scanlon,
and Querec ( 1970) assessed some similar indices of psychological distress
with a representative national probability sample of more than 7,000 persons.
More recent data focusing on similar indices of psychopathology were collected in Epidemiologic Catchment Area Study (ECAS), a multisite study in
which the diagnostic interview schedule (DIS) was used to assess the prevalence of psychiatric symptoms in the population at large (Robins & Regier,



1991 ). Finally, even more extensive comparisons are possible with another
systematic study of the effects of living under isolated prison conditionsBrodsky and Scogin's (1988) research on prisoners confined in two maximum security protective custody units.
Table 3 contains a summary of the comparisons between the prevalence
rates found in the two studies of nonincarcerated normal populations,
Brodsky and Scogin's protective custody prisoners, and the supermax sample
from Pelican Bay SHU (of course, along only those dimensions measured in
each of the respective studies). The contrasts with the nonincarcerated normal samples are striking. As would be expected, in almost every instance, the
prevalence rates for indices of psychological distress and psychopathology in
the samples from the general population are quite low. The only exceptions
were for anxiety and nervousness, which Dupuy et al. ( 1970) found in 45% of
their normal sample, and depression, which Robins and Regier (1991) found
in almost a quarter of the persons they assessed. Otherwise, the indices of distress and symptoms of psychopathology occurred in less than 20% of the
nonincarcerated samples. On the other hand, in both of the isolated prisoner
populations, the prevalence rates were well above 50% on virtually all of the
measured dimensions. For certain symptoms, rates for the prisoner samples
were five to ten or more times as high.
In fact, in both comparative and absolute terms, the prevalence rates were
extremely high for the supermax prisoner sample and exceeded even those
reported for the protective custody prisoners. Conditions ofconfinement for
protective custody prisoners are in many ways similar to those in supermax
confinement. That is, they are typically segregated from the rest of the prison
population, restricted or prohibited from participating in prison programs
and activities, and often housed indefinitely under what amount to oppressive
and isolated conditions. Unlike supermax prisoners per se, however, many
have some control over their status as protective custody (PC) prisoners (e.g.,
many have "volunteered" for this status) and, although they live under the
stigma of being PC prisoners, they are technically housed in these units for
protection rather than for punishment.
Accordingly, Brodsky and Scogin ( 1988) found high rates of psychological trauma among their sample of protective custody prisoners, so much so
that they worried about the "strong potential for harmful effects" that such
confinement represented (p. 279).8 They also observed, in terms that apply
equally well to supermax prisoners, that "when inmates are subjected to
extensive cell confinement and deprivation of activities and stimulation, a
majority can be expected to report moderate to serious psychological symptoms" (p. 279). Yet, note that on 16 of 18 possible comparisons, the symptom
prevalence rate for Pelican Bay SHU prisoners are greater than those reported



TABLE 3: Comparison of Prevalence Rates Between In Normal, Protective Custody, and Supermax Populations


Symptoms of psychological trauma
Anxiety, nervousness
Lethargy, chronic tiredness
Trouble sleeping
Impending breakdown
Perspiring hands
Heart palpitations
Hands trembling
Psychopathological effects of Isolation
Irrational anger
Confused thought process
Chronic depression
Overall deterioration
Talking to self

.Dupuy, Engel,
Devine, Scanlon,
and Querec's (1970}
National Probability
Sample of 7,000 Adults

Robins and
Regier's (1991)
Multlsite Assessment
of 20,000 Adults



% Protective Housing
Brodsky and
Scoggin's (1988)
Prisoners In
Protective Housing

% Supermax
Haney's (1993)
Random Sample
of 100 Prisoners in
Security Housing Unit









in the protective custody study. Note .also that many of the percentage differences are comparatively large. In fact, the Pelican Bay prevalence rates are,
on average, 14.5% greater than those reported for the prisoners in Brodsky
and Scogin's study.
The prevalence data collected in the Pelican Bay study partially address
another important supermax-related issue. Several mental health experts
have written about a distinct set of reactions or a syndrome-like condition that
occurs in prisoners who have been subjected to long-term isolation. Canadian
psychiatrist George Scott (1969) described what he termed "isolation sickness" as coming from "prolonged solitary confinement" (p. 3). In more
recent research, it has been labled "RES" (reduced environmental stimulation) or "SHU" (security housing unit) syndrome. Perhaps the most detailed
clinical description of the disorder came from psychiatrist Stuart Grassian
(1983), who observed that it included massive free-floating anxiety, hypersensitivity to external stimulation, perceptual distortions or hallucinations,.
derealization experiences, difficulties with concentration or memory, acute
confusional states, aggressive fantasies, paranoia, and motor excitement (that
may include violent or self-destructive outbursts).
Because the Pelican Bay prevalence study was not designed to directly
diagnose SHU syndrome, prisoners were not questioned about literally each
one of its indices. However, the study found that a very high percentage of
Pelican Bay prisoners suffered many symptoms similar to the ones Grassian
had identified. Specifically, a high percentage of prisoners in the present
study reported suffering from heightened anxiety (91% ), hyper-responsivity
to external stimuli (86% ), difficulty with concentration and memory (84% ),
confused thought processes (84% ), wide mood and emotional swings (71% ),
aggressive fantasies (61% ), perceptual distortions (44% ), and hallucinations
(41%). Moreover, fully 34% of the sample experienced all eight of these
symptoms, and more than half (56%) experienced at least five of them.


The Pelican Bay prevalence study and the other direct studies of the psychological effects of supermax confinement I cited earlier focused on discrete and measurable consequences of this form of imprisonment. The tools
used to provide these measurements are extremely useful and scientifically
appropriate methods for documenting specific reactions and symptoms.
However, they have some inherent limitations that may mask some of the
subtle yet important transformations that are brought about by supermax



For one, indices of measurable harm generally rely on things that persons
must be aware of in order to report. Obviously, prisoners must be consciously
pained or in distress over a symptom in order to complain about it; the greater
their conscious awareness, the higher the frequency and extent of negative
effects. However, in the course of adjusting and adapting to the painful and
distressing conditions of confinement, many prisoners will strive to essentially "get used to it," adapting and accommodating to make their day-to-day
misery seem more manageable. In addition, some supermax prisoners will
undergo forms of psychological deterioration of which they are unaware and,
therefore, incapable of reporting. As long as the deterioration is not obvious
or disabling, it is likely to escape the attention of mental health staff who, in
most units, rarely perform careful psychiatric assessments on a routine basis
for prisoners who appear to be otherwise minimally functioning.
Indeed, it is not uncommon to encounter a number of supermax prisoners
who, although they voice few specific complaints and are not identified by
staff as having any noticeable psychological problems or needs, nonetheless
have accommodated so profoundly to the supermax environment that they
may be unable to live anywhere else. In some instances, these changes are difficult to measure because prisoners are unaware that they are occurring or
because they have blunted their perception that such transformations are
underway. In other instances, the changes are too broad, complicated, and
subtle to be precisely measured. Yet they appear to have lasting mental health
Thus, a number of significant transformations occur in many long-term
supermax prisoners that, although they are more difficult to measure, may be
equally if not more problematic for their future health and well-being and the
health and well-being of those around them. These come about because in
order to survive the rigors of supermax, many prisoners gradually change
their patterns of thinking, acting, and feeling. Some of these transformations
have the potential to rigidify, to become deeply set ways of being, that are, in
varying degrees for different people, more or less permanent changes in who
these prisoners are and, once they are released from supermax, what they can
become. Because they do not represent clinical syndromes per se, and
because they constitute patterns of social behavior that are largely "functional" under conditions of isolation-for the most part becoming increasingly dysfunctional only if they persist on return to more normal social settings-! have termed them "social pathologies."
Several of the social pathologies that can and do develop in prisoners who
struggle to adapt to the rigors of supermax confinement are discussed below.
First, the unprecedented totality of control in supermax units forces prisoners to become entirely dependent on the institution to organize their exis-



tence. Although this is a potential consequence of institutionalization or
"prisonization" in general (e.g., Haney, in press), it occurs to an exaggerated
degree in many supermax prisons. Thus, many prisoners gradually lose the
ability to initiate or to control their own behavior, or to organize their own
lives. The two separate components of this reaction-problems with the selfcontrol and self-initiation of behavior-both stem from the extreme overcontrol of supermax. That is, all prisoners in these units are forced to adapt to
an institutional regime that limits virtually all aspects of their behavior.
Indeed, one of the defining characteristics of supermax confinement is the
extent to which it accomplishes precisely that. But because almost every
aspect of the prisoners' day-to-day existence is so carefully and completely
circumscribed in these units, some of them lose the ability to set limits for
themselves or to control their own behavior through internal mechanisms.
They may become uncomfortable with even small amounts of freedom
because they have lost the sense of how to behave in the absence of constantly
enforced restrictions, tight external structure, and the ubiquitous physical
Second, prisoners may also suffer a seemingly opposite reaction that is
caused by the same set of circumstances. That is, they may begin to lose the
ability to initiate behavior of any kind-to organize their own lives around
activity and purpose-because they have been stripped of any opportunity to
do so for such prolonged periods of time. Chronic apathy, lethargy, depression, and despair often result. Thus, as their personal initiative erodes, prisoners find themselves unable to begin even mundane tasks or to follow through
once they have begun them. Others find it difficult to focus their attention, to
concentrate, or to organize activity. In extreme cases, prisoners may literally
stop behaving. In either event, it is hard to imagine a set of adaptations more
dysfunctional and problematic for persons who will one day be expected to
exercise increased self-control and self-initiative in mainline prison settings
or in the free world, if and when they are released there.
Third, the absence of regular, normal interpersonal contact and any semblance of a meaningful social context creates a feeling of unreality that pervades one's existence in these places. Because so much of our individual
identity is socially constructed and maintained, the virtually complete loss of
genuine forms of social contact and the absence of any routine and recurring
opportunities to ground one's thoughts and feelings in a recognizable human
context leads to an undermining of the sense of self and a disconnection of
experience from meaning. Supermax prisoners are literally at risk of losing
their grasp on who they are, of how and whether they are connected to a larger
social world. Some prisoners act out literally as a way of getting a reaction
from their environment, proving to themselves that they are still alive and



capable of eliciting a genuine response-however hostile-from other human
Fourth, the experience of total social isolation can lead, paradoxically, to
social withdrawal for some supermax prisoners. That is, they recede even
more deeply into themselves than the sheer physical isolation of supermax
has imposed on them. Some move from, at first, being starved for social contact to, eventually, being disoriented and even frightened by it. As they
become increasingly unfamiliar and uncomfortable with social interaction,
they are further alienated from others and made anxious in their presence. In
extreme cases, another pattern emerges: This environment is so painful, so
bizarre and impossible to make sense of, that they create their own realitythey live in a world of fantasy instead.
Fifth, and finally, the deprivations, restrictions, the totality of control, and
the prolonged absence of any real opportunity for happiness or joy fills many
prisoners with intolerable levels of frustration that, for some, turns to anger
and then even to uncontrollable and sudden outbursts of rage. Others channel
their supermax-created anger in more premeditated ways. Many supermax
prisoners ruminate in the course of the countless empty hours of uninterrupted time during which they are allowed to do little else. Some occupy this
idle time by committing themselves to fighting against the system and the
people that surround, provoke, deny, thwart, and oppress them. There are
supermax prisoners who become consumed by the fantasy of revenge, and
others lash out against those who have treated them in ways they regard as
inhumane. Sadly, there are some supermax prisoners who are driven by these
deprived and oppressive conditions to pursue courses of action that further
ensure their continued deprivation and oppression.
Although I have described these social pathologies as separate and distinct
adaptations, they are not mutually exclusive. Thus, prisoners may move
through one or another adaptation to their extraordinarily stressful life in
supermax, or engage in several at once in an attempt to reduce the pains of
their confinement and to achieve a tolerable equilibrium in this otherwise
psychologically hostile environment. In fact, in extreme cases and over a long
period of time, a combination of seemingly adaptive responses may coalesce
into a more or less permanent lifestyle, one lived so exclusively and with such
commitment that the prisoner's very being seems to be transformed. For
example, some supermax prisoners whose opportunities for self-definition
and self-expression have been effectively suppressed for extended periods of
time-who have been denied conventional outlets through which to use their
intellect or to express their heightened sense of injustice-come increasingly
to define themselves in opposition to the prison administration. They begin to
gradually fashion an identity that is anchored primarily by the goal of thwart-



ing and resisting the control mechanisms that are increasingly directed at
them. The material out of which their social reality is constructed increasingly consists of the only events to which they are exposed and the only experiences they are allowed to have-the minutiae of the supermax itself and all
of the nuance with which it can be infused.
Just as the social pathologies of supermax are the creations of a socially
pathological environment, taking prisoners out of these places often goes a
long way in reducing or eliminating the negative effects. But there is good
reason to believe that some prisoners-we do not yet know how many or, in
advance, precisely who-cannot and will not overcome these social pathologies; their extreme adaptations to supermax confinement become too
ingrained to relinquish. Those who are not blessed with special personal
resiliency and significant social and professional support needed to recover
from such atypical and traumatic experiences may never return to the free
world and resume normal, healthy, productive social lives. These are extraordinary-! believe often needless and indefensible-risks to take with the
human psyche and spirit. Such extreme, ultimately dysfunctional, but often
psychologically necessary adaptations to supermax confinement underscore
the importance of continuing to critically analyze, modify, and reform the
extremely harsh conditions that produce them. Understanding how and why
they occur also brings some real urgency to the development of effective programs by which prisoners can be assisted in unlearning problematic habits of
thinking, feeling, and acting on which their psychological survival in supermax often depends.
But they also highlight another issue. In what is one of the core irrationalities in the logic on which supermax regimes are premised, these units make
the ability to withstand the psychological assault of extreme isolation a prerequisite for allowing prisoners to return to the intensely social world of
mainline prison or free society. In this way, prisoners who cannot "handle"
the profound isolation of supermax confinement are almost always doomed
to be retained in it. And those who have adapted all too well to the deprivation, restriction, and pervasive control are prime candidates for release to a
social world to which they may be incapable of ever fullx readjusting.

In addition to the negative psychological effects of solitary and supermaxlike confinement reviewed above, there are several other important mental
health issues raised by the nature of these conditions and the policies by



which prisoners are placed in them. One such issue involves the number of
mentally ill prisoners who are housed in supermax. Prisoners often describe
their experience in supermax environments as a form of psychological torture; most of them are in varying degrees of psychic pain, and many of them
struggle to cope with the daily stress of their confinement. Although in my
experience, virtually everyone in these units suffers, prisoners with preexisting mental illnesses are at greater risk of having this suffering deepen into
something more permanent and disabling. Those at greatest risk include, certainly, persons who are emotionally unstable, who suffer from clinical
depression or other mood disorders, who are developmentally disabled, and
those whose contact with reality is already tenuous. There is good reason to
believe that many of these prisoners in particular will be unable to withstand
the psychic assault of dehumanized isolation, the lack of caring human contact, the profound idleness and inactivity, and the otherwise extraordinarily
stressful nature of supermax confinement without significant deterioration
and decompensation.
How many such persons are there? Research conducted over the past several decades suggests that somewhere between 10% to 20% of mainline prisoners in general in the United States suffer from some form of major mental
illness (e.g., Jamelka, Trupin, & Chiles, 1989; Veneziano & Veneziano,
1996). The percentages in supermax appear to be much higher. Although too
few studies have been done to settle on precise estimates of mentally ill
supermax prisoners, and the numbers undoubtedly vary some from prison
system to prison system, the percentages may be as much as twice as high as
in the general prisoner population.
For example, a Canadian study estimated that approximately 29% of prisoners in special handling and long-term segregation units suffered from
"severe mental disorders" (Hodgins & Cote, 1991 ). A more recent study conducted by a group of Washington state researchers (Lovell, Cloyes, Allen, &
Rhodes, 2000) found exactly the same thing: 29% of intensive management
prisoners in the state's correctional system manifested at least one predefined
indication of serious mental disorder (such as multiple admissions to an acute
care mental care facility, or having been in one of the prison system's residential mental health units).
Why this overrepresentation? Unproblematic adjustment to prison
requires conformity to rigidly enforced rules and highly regimented procedures. Many mentally ill prisoners lack the capacity to comply with these
demands and they may end up in trouble as a result. If they are not treated for
their problems, the pattern is likely to be repeated and eventually can lead to
confinement in a supermax unit. As Toch and Adams (2002) have succinctly
put it, "an unknown proportion of people who are problems (prove trouble-



some to settings in which they function) also have problems (demonstrate
psychological and social deficits when they are subjected to closer scrutiny)"
(p. 13). Prison systems that fail to realize this basic fact will end up blaming-and punishing-prisoners for manifesting psychological conditions
for which they should have been treated. Especially for prison systems that
lack sufficient resources to adequately address the needs of their mentally ill
mainline prisoners, disciplinary isolation and supermax confinement seems
to offer a neat solution to an otherwise difficult dilemma. In such systems,
supermax becomes the default placement for disruptive, troublesome, or
inconvenient mentally ill prisoners. Thus the presence of a disproportionately high number of mentally ill prisoners in supermax often reflects a failure of system-wide proportions.
A number of supermax prisons fail to adequately screen out prisoners with
preexisting mental illness, and fail to remove those whose mental health
problems worsen under the stress of the extreme isolation, deprivation, and
forceful control they confront inside. In addition, many of the units fail to
appreciate the potential for these kinds of conditions of confinement to produce psychopathology in previously healthy prisoners. These problems are
exacerbated by the fact that even if mental health staff members manage to
identify those prisoners with serious psychological and psychiatric needs,
many supermaxes are 'uniquely ill-suited to address them. Not only are they
likely to be staffed with too few treatment personnel and plagued by high
turnover, but the extraordinary and unyielding security procedures that characterize these kinds of prisons often preclude meaningful and appropriate
therapeutic contact.
Thus, supermax prisoners who are in acute distress typically have the
option of receiving what is euphemistically called ..cell front therapy" in
which they can discuss intimate, personal problems with mental health staff
who cannot easily see or hear them through the cell doors (unless they speak
so loudly that other prisoners in the housing unit also can listen in). Or they
can choose to undergo strip searches, be placed in multiple restraints (which
are typically left on throughout the therapy session), and taken either to a
counselor's office (where correctional officer escorts are often stationed
close enough to overhear what is being said) or special rooms fitted with
security cages in which the prisoner is placed to be counseled by a therapist
who speaks to them through wire screening of the cage. Or, in some places
they can submit to "tele-psychiatry" sessions in which disembodied images
attempt to assess and address their problems from distant locations. Not surprisingly, under these circumstances many prisoners fail to ask for help or
reject it when it is offered.
A separate but related problem pertains to the group of prisoners who,
although they do not suffer from preexisting mental illness, nonetheless are



psychologically damaged by the extreme situational stress to which they are
subjected in supermax. There is much reason to believe that supermax confinement may produce psychopathology in certain persons who otherwise
would not have suffered it. For example, a study of Danish prisoners found
that for prisoners who remained in solitary confinement for longer than 4
weeks "the probability of being admitted to the prison hospital for a psychiatric reason was about 20 times as high as for a person [in a mainline prison]"
(Sestoft et al., 1998, p. 103), leading the researchers to conclude that "individuals detained [in solitary confinement] are forced into an environment that
increases their risk of hospitalization ...for psychiatric reasons" (p. 105).
Finally, as I earlier alluded, many of the psychological and psychiatric
reactions created or exacerbated by supermax confinement may persist long
after a prisoner has been released into the mainline population or freed from
incarceration altogether. In addition, even among prisoners who suffer no
readily identifiable set of psychological symptoms, the social pathologies of
supermax confinement may significantly interfere with long-term adjustment. To date, most supermax prisons appear oblivious to these persistent
problems and many offer no meaningful counseling or transitional programs
at all to prisoners who are attempting to make the daunting adjustment from
near total isolation to an intensely social existence.
These interrelated problems-that prisoners suffering from preexisting
mental illnesses are overrepresented in supermax, that the pains of supermax
confinement are too severe for many prisoners to withstand, and that many of
the psycho- and social pathologies of supermax confinement have disabling
long-term consequences-have several important correctional policy implications. In particular, procedures must be implemented for screening prisoners in advance of their transfer to supermax (so that mentally ill and otherwise
vulnerable persons are never placed there in the first place). In addition,
because the mental health needs of any supermax prisoner can become acute
and substantial at any time, prison systems need to be fully prepared to adequately address them (setting aside the obvious question of whether anyone
can and should, in a humane system, be housed in such environments in the
first place).
This also means that supermax prisons must implement careful psychiatric monitoring of all prisoners during their confinement and have readily
accessible procedures in place for the removal of any prisoner at the first sign
of deterioration. Given the fact that supermax prisoners behave so littlethey are not permitted to actually do much of anything-the opportunities for
disturbed behavior to be observed by staff are extremely limited. If monitoring is done passively, as it often is, only the most flagrant cases are likely to
come to anyone's attention. Mental health staff who walk through supermax



housing units, pausing briefly at each cell to ask prisoners how they are doing
or to pose some other equally superficial, pro forma inquiry are not engaging
in careful psychiatric screening. In light of the psychological risks posed by
this environment and the widely shared reluctance of these prisoners to admit
vulnerability, the regular and in-depth evaluation of supermax prisoners
should be regarded as the only acceptable and truly effective form of
Finally, supermax units should be required to provide extensive mental
health resources that are specifically targeted to ease the psychological pains
of this kind of confinement and the extremely difficult transitions that typically follow it. Supermax prisoners must enter so-called de-escalation or
step-down programs well in advance of their release, and the programs themselves must grapple seriously and forthrightly with the negative psychological changes that supermax confinement often brings about. This will require
prison systems that are in denial about the issues reviewed in the preceding
pages to overcome it, and to acknowledge and confront the psychological
consequences of housing prisoners under conditions that pose such significant mental health risks. Attempts to provide these kinds of transitional services through programs that are delivered without genuine interpersonal
interaction and social contact-some systems actually use videotapes that
supermax prisoners watch alone in their cells, supposedly to reacquaint them
with the social world they are about to reenter-will prove to be painfully
inadequate. Moreover, like all meaningful mental health and counseling services, these transitional programs must be made available to prisoners under
genuinely therapeutic conditions that foster some degree of privacy, trust,
and supportive social interaction.


Because supermax prisons are of relatively recent origin, their constitutionality-the question of whether the conditions of confinement in this new
prison form represent cruel and unusual punishment-has been tested in only
a few important cases. In this section, I review the three most important
legal challenges to supermax confinement and examine the implications
of the way in which the courts have responded in each. Judges in all three
cases recognized the need for some form of segregated housing in correctional settings, emphatically acknowledged-with varying degrees of clarity
and scope-the potential psychological harms of supermax-type confinement, and explicitly prohibited certain categories of prisoners from being
housed under such conditions.



The first such case, Madrid v. Gomez ( 1995), addressed conditions of confinement in California's Pelican Bay Security Housing Unit, the site at which
my earlier reported research was conducted. The judge was candid and critical in his assessment of the conditions of confinement in the California
supermax. He pointed to the "stark sterility and unremitting monotony" of
the interior of the prison itself, was concerned about the fact that prisoners
"can go weeks, months or potentially years with little or no opportunity for
normal social contact with other people," and commented that the sight of
prisoners in the barren exercise pens to which they were restricted creating an
image "hauntingly similar to that of caged felines pacing in a zoo" (p. 1229).
He found further that "many, if not most, inmates in the SHU experience
some degree of psychological trauma in reaction to their extreme social isolation and the severely restricted environmental stimulation in the SHU"
(p. 1235). Indeed, the court's opinion acknowledged that "social science and
clinical literature have consistently reported that when human beings are subjected to social isolation and reduced environmental stimulation, they may
deteriorate mentally and in some cases develop psychiatric disturbances"
(p. 1230). He concluded that Pelican Bay inflicted treatment on prisoners
that, in his words, "may well hover on the edge of what is humanly tolerable
for those with normal resilience, particularly when endured for extended
periods of time" (p. 1280).
However, although the judge in Madrid also found that overall conditions
in the supermax units were "harsher than necessary to accommodate the
needs of the institution" (p. 1263), he concluded that he lacked any constitutional basis to close the prison or even to require significant modifications in
many of its general conditions. Instead, he barred certain categories of prisoners from being sent there because of the tendency of the facility to literally
make them mentally ill or significantly exacerbate preexisting mental illness.
In particular, he limited the class of prisoners to be protected from these
harms to the mentally ill and those prisoners who were at an unreasonably
high risk of suffering a serious mental illness as a result of the conditions
(including prisoners diagnosed as chronically depressed, brain damaged, and
developmentally disabled). 8 Finally, the judge emphasized that the record
before him pertained to prisoners who had been in supermax for no more than
a few years and that longer term exposure might require a different result. 9
In the second significant case to examine conditions of confinement in
supermax-like settings, Ruiz v. Johnson (1999), a federal district court
reached even more sweeping legal conclusions than the judge had in Madrid.
For nearly 30 years, the Ruiz court had overseen the sweeping reform of the
Texas prison system. Starting with a landmark opinion in 1980 in which the
entire Texas prison system was declared unconstitutional (Ruiz v. Estelle,



1980), an extensive number of court-ordered changes had been implemented.
Hoping to end this judicial oversight, the state petitioned to terminate the
court's jurisdiction, arguing that a sufficient number of reforms had been
made in the Thxas prison system and that no unconstitutional conditions of
confinement remained. The federal court agreed on some counts but disagreed emphatically on others.
Conditions of confinement in Texas's "administrative segregation" or
"high s~urity" units were a major part of this round of the Ruiz litigation.
Despite acknowledging significant improvements in many other areas of the
state's prison system, the court ruled that its disciplinary lockup units still
operated below constitutionally minimum standards. In particular, the judge
ruled that the "extreme deprivations and repressive conditions of confinement" of the administrative segregation units constituted cruel and unusual
punishment "both as to the plaintiff class generally and to the subclass of
mentally ill inmates housed in such confinement" (p. 861 ). Indeed, the judge
concluded that "more than mere deprivation," the prisoners in these units
"suffer actual psychological harm from the almost total deprivation of human
contact, mental [stimulation], personal property and human dignity" (p. 913).
The judge also understood that the psychological harm inflicted by longterm supermax confinement could result in mental illness, even among those
prisoners not previously afflicted. Thus, the court concluded that "Texas's
administrative segregation units are virtual incubators of psychoses-seeding illness in otherwise healthy inmates and exacerbating illness in those
already suffering from mental infirmities" (p. 907). The judge was clear and
decisive in his ruling, writing that "it is found that administrative segregation
is being utilized unconstitutionally to house mentally ill inmates-inmates
whose illness can only be exacerbated by the depravity of their confinement"
(p. 915).
He further speculated about why prison officials, who were clearly aware
of these conditions and cognizant of the "inmates' ensuing pain and suffering" might maintain such a system. Whatever the cause-including the possibility that the officials labored under what he termed "a misconception of
the reality of psychological pain"-the judge condemned the fact that the
prison system had "knowingly turned its back on this most needy segment of
its population" (p. 914). 10
The final and most recent case, Jones 'El v. Berge (2001), presented a
somewhat narrower issue but resulted in a similarly strong ruling. In this
case, a federal district court in Wisconsin granted prisoners' motion for
injunctive relief on the grounds that seriously mentally ill prisoners were at
risk of irreparable emotional damage if the state continued to confine them;in
its supermax facility. The court concluded that the



extremely isolating conditions in supermaximum confinement cause SHU
Syndrome in relatively healthy prisoners who have histories of serious mental
illness, as well as prisoners who have never suffered a breakdown in the past
but are prone to break down when the stress and trauma become exceptionally
severe. (pp. 1101-1102)
The court found further that
credible evidence indicates that Supermax is not appropriate for seriously
mentally ill inmates because of the isolation resulting from the physical layout,
the inadequate level of staffing and the customs and policies. Supermax was
designed to house especially disruptive and recalcitrant prisoners but not mentally ill ones. (p. 1118)
The judge ordered several prisoners to be removed from the supermax facility. In addition, she required mental health professionals to evaluate several
categories of prisoners among those who remained, and if any of them were
determined to be seriously mentally ill, she ordered that they be transferred
out of supermax.
In each of these three cases in which federal district courts were presented
with evidence of the psychological effects of supermax confinement, they
acknowledged the significant psychological risks it posed, expressed
strongly worded concerns about the constitutionality of exposing prisoners to
these conditions for long periods of time, and expressly prohibited the use of
supermax for certain categories of prisoners (in particular, those with preexisting histories of mental illness, and those likely to become mentally ill in the
course of their solitary confinement).



Supermax prisons inflict varying amounts of psychological pain and emotional trauma on prisoners confined in them. The range of
psychopathological reactions to this form of confinement is broad, many of
the reactions are serious, and the existing evidence on the prevalence of
trauma and symptomatology indicates that they are widespread. The mental
health risks posed by this new form of imprisonment are clear and direct,
exacerbated by the tendency of correctional systems to place a disproportionate number of previously mentally ill prisoners in supermax confinement, to
ignore emerging signs of mental illness among the supermax prison population, and to fail to provide fully adequate therapeutic assistance to those prisoners who are in psychic pain and emotional distress.



It is important to reflect on whether the psychologically destructive conditions to which prisoners in supermax prisons are exposed would be countenanced for any other group in our society. Indeed, revelations that mental
patients or elderly nursing home residents have been subjected to punitive
isolation are understandably followed by widespread public outcry. Similarly, when typically more psychologically resilient populations have been
taken as prisoners of war or as hostages subsequently held in isolation, recognition of the adverse psychological consequences is immediate and generates
broad concern. Support for providing psychiatric counseling to the victims of
these kinds of traumatic experiences is unquestioned.
The fact that no such recognition and concern is typically extended to prisoners in supermax confinement whose experiences in captivity may be comparable or worse, and of longer duration, raises disturbing questions: Do we
allow what we believe to be their blameworthiness for this kind of mistreatment-that they earned it, they deserve it, they asked for it-to blur our
understanding of the consequences of the mistreatment itself? That is, has
devaluing the prisoners' claim to be free from such harm led to the erroneous
perception that the harm is not real? If so, the empirical evidence suggests
that we have made a grievous mistake.
I believe that the overwhelming evidence of the negative psychological
effects of many forms of long-term supermax confinement provides a strong
argument for placing enhanced correctional and legal limits on the use of this
new prison form and carefully scrutinizing all aspects of its operation and
effect (e.g., Haney & Lynch, 1997, pp. 558-566). As I noted earlier, there are
better and worse supermax prisons, and we should take steps to ensure that all
such facilities implement the best and most humane of the available practices. In general, far more careful screening, monitoring, and removal policies should be implemented to ensure that psychologically vulnerable-not
just mentally ill-prisoners do not end up in supermax in the first place, and
that those who deteriorate once there are immediately identified and transferred to less psychologically stressful environments. In addition, prison disciplinary committees should ensure that no prisoner is sent to supermax for
infractions that were the result of preexisting psychiatric disorders or mental
illness. 11
Moreover, harsh supermax conditions of confinement themselves must be
modified to lessen their harmful effects. That is, it is important to recognize
that placing people in conditions of confinement that we know in advance are
likely to psychologically harm and endanger them cannot be morally justified merely through assurances that, if and when they do deteriorate, the
prison system will make a good faith effort to identify the damage and work
reasonably diligently to repair it. Thus, meaningful activities and program-



ming-including access to therapy, work, education, and recreation-should
be afforded all supermax prisoners to prevent deterioration, and out-of-cell
time should be maximized within the limits of correctional resources. To prevent the total atrophy of social skills and the deterioration of social identities,
supermax prisoners should be afforded some form of meaningful collective
activity and opportunities for normal social interaction (that includes contact
Finally, strict time limits should be placed on the length of time that prisoners are housed in supermax. No prisoner should be subjected continuously
to even these modified conditions of supermax-like confinement for longer
than a period of2 years, no prisoner should ever be subjected to indeterminate
supermax terms for any reason, and no prisoner should be sent to supermax
solely on the basis of alleged gang membership in the complete absence of
other overt behavioral infractions. Indeed, the units themselves should be
organized around the goal of rapid return and reintegration and judged on the
basis of their ability to release rather than retain prisoners. Once prisoners are
about to be released from supermax confinement, they should be afforded
transitional or step-down programming to accustom them to the kind of environment to which they will be sent (mainline prison housing or the free
world). Moreover, given the likely long-term effects of such confinement,
these transitional programs and services should be continued after the prisoner has been transferred from supermax.
Correctional administrators, politicians, legal decision makers, and members of the public eventually may decide that the harm that supermax prisons
inflict is worth the benefit that they arguably beget and that the pains of such
confinement are the regrettable but unavoidable price of an otherwise justified policy. However, there are very serious psychological, correctional,
legal, and even moral issues at the core of this calculation that are worthy of
serious, continued debate. This debate has hardly begun and, in most
instances, it has hardly been informed by the empirical record that I have
cited in the preceding pages.
Many scholars who have studied supermax prisons-myself includeddoubt the validity of the claims that are made on their behalf, 12 and believe
that in any event many of the publicly asserted goals of this new form of
imprisonment can be achieved through less psychologically onerous and
invasive alternatives. Yet, whatever one concludes about the value of
supermax prisons in achieving these goals, it represents only one term in a
more complex equation. The important determination of what, if any, legitimate role this kind of imprisonment should have in an effective and humane
prison system can only be made with its psychological effects clearly in
mind. The best available evidence indicates very clearly that many



supermax-like conditions of confinement inflict extraordinary levels of psychological pain and create substantial mental health risks. We should not continue to ignore, overlook, or minimize these data in this continuing and
important debate.

1. I have chosen to use the more encompassing term supermax prison even though it is
rarely used as the official designation for such places. Different prison systems use different terminology to refer to these kinds of units. For example, the program at Marion Penitentiary generally regarded as having given rise to the supermax design was referred to as the "control unit."
Arizona's supermax units are called ""special management units" or''SMUs"; in California, they
are known as "security housing units," or "SHUs"; in Texas, they are "high security units";
Washington State employs the term "intensive management unit" or ''IMU ,"whereas New Mexico prefers "special controls unit" or "SCU." Although penologist Chao;e Riveland ( 1999) was
correct to conclude that "there is no universal definition of what supermax facilities are and who
should he in them" (p. 4), most of these units, whatever they are called, have enough distinctive
features in common to be analyzed together.
2. Few "isolation" units, including supermax prisons, have been able to successfully prevent literally all forms of interpersonal communication. Of necessity, prisoners in solitary confinement must have some form of regular and routine contact with staff. In addition, the physical
layouts of most such units-adjoining cells connected by plumbing, heating vents, and ventilation ducts-typically allow for some minimal form communication between prisoners (however
strained and denatured the "interaction" may be and however inventive prisoners must be to
bring it about).
3. Long-term solitary confinement was once a standard feature of imprisonment. But by the
last decade of the 19th century, it essentially had been abandoned (see Haney & Lynch, 1997, pp.
481-496). In 1890, U.S. Supreme Court Justice Miller (Re Medley, 1890), summarized the preceding hundred years of experience with this kind of punishment by noting,"1bere were serious
objections to it ... and solitary confinement was found to be too severe." To illustrate, he also provided this account of its psychological effects:
A considerable number of the prisoners feU, after even a short confinement, into a semifatuous condition, from which it was next to impossible to arouse them, and others
became violently insane; others still, committed suicide; although 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. (p. 168)
4. In some jurisdictions, overcrowding in these units ha~ forced prison officials to doublecell supermax prisoners. In a sense, this kind of confinement leaves prisoners simultaneously
and paradoxically isolated and overcrowded.
5. Most states conduct periodic reviews of such indeterminate sentences. But the reviews
are typically pro forma and continued supermax placement is virtually always authorized. Since
the initial decision about a prisoner's status as a gang member is based entirely on the judgement
of staff members, and since these judgements rarely if ever change, continued and indefinite
supermax placement is essentially assured. See Tachiki ( 1995) for a more detailed discussion of
this issue.



6. What, ellactly, qualifies a prisoner to be considered one of the so-called "worst of the
worst" has never really been clarified in correctional policy or constitutional decision making.
Nonetheless, correctional administrators (e.g., Hershberger, 1998) and even some federal judges
talk about the category as though it was unproblematic to define and apply. For example, "Common sense, moreover, tells us that the prisoners in the disciplinary unit of a ma11imum security
prison are apt to be the worst of the worst and that guards must therefore use more repressive
methods in dealing with them" (Cooper v. Casey, 1996, p. 918). See, also, Jones 'El 1~ Berge
(2001): "Supermall Correctional Institution is a 500 bed superma11imum security facility in
Boscobel, Wisconsin, designed to incarcerate the worst of the worst offenders" (p. 1099). However, as another federal judge correctly observed, "this concept has proven difficult to
operationalize" (Austin v. Wilkinson, 2002, p. 723). Critics have questioned the use ofthis terminology and worry that its vagueness leads repeatedly to overclassification and the blanket justification for harsh treatmenL When it is applied to prisoners solely on the basis of alleged gang
affiliation or in response to disciplinary infractions that, in at least some instances, appear to stem
more from mental illness than willful propensities on the part of the prisoner, it seems particularly questionable and subject to abuse. See, for e11ample, DeMaio (2001) and Tachiki (1995).
7. Random sampling of prisoners permits the sample statistics to be generalized to the characteristics of the entire SHU population, within a margin of error associated with the particular
estimate. This margin of error is a function of both the size of the sample (in this case, 102) and
the specific sample percentage being generali7.ed. For example, at the 95% confidence level (the
level ordinarily used in academic and scientific writing), the margin of error for this sample is
somewhere between ±6% to I 0%, depending on the specific sample percentage. The more even
the percentage split (i.e., 50%), the closer to the higher limit (in this case ±10%) the margin of
error will be.
8. In a key passage in the opinion, the judge (Madrid v. Gomez, 1995) limited his ruling in
this way:
While a risk of a more serious [mental] injury is not non-existent, we are not persuaded,
on the present record and given all the circumstances, that the risk of developing an injury
to mental health of sufficiently serious magnitude due to current conditions in the SHU is
high enough for the SHU population as a whole, to find that current conditions in the
SHU are per se violative of the Eighth Amendment with respect to all potential inmates.
(p. 1265)
9. He wrote, "We emphasize, of course, that this determination is based on the current
rec_oJ:P. and data before us. We can not begin to speculate on the impact that Pelican Bay SHU
conditions may have on inmates confined in the SHU for periods of 10 or 20 years or more; the
inmates studied in connection with this action had generally been confined to the SHU for three
years or less" (Madrid v. Gomez, 1995, p. 1267).
I 0. A short time later in the opinion, the judge was equally pointed in his analysis:
As the pain and suffering caused by a cat-o' -nine-tails lashing an inmate's back are cruel
and unusual punishment by today's standards of humanity and decency, the pain and suffering caused by extreme levels of psychological deprivation are equally, if not more,
cruel and unusual. The wounds and resulting scars, while Jess tangible, are no less painful and permanent when they are inflicted on the human psyche. (p. 914)
II. It is important not to be naive about vague recommendations like "screening, monitoring,
and removal." The utility of these reforms turns entirely on the way in which they are actually
implemented. For example, if mental health personnel must always defer to the judgements of
custodial staff, are under pressure to admit or retain prisoners in supermall whom they believe
should not be there, are inadequately trained to recognize vulnerabilities to isolation-related



stressors, or predisposed to attribute psychiatric complaints to preexisting character disorders
(and thereby dismiss them}, then the reforms will help to ameliorate the harms of supermax very
little or not at all.
12. For example, "Not one of the state supermax prisons, however, is necessary, and all are a
grave error in the sad tale of man's brutality to man" (Kurki & Morris, 2001, p. 421); "Where
prison regimes are so depriving as those offered in most supermax facilities, the onus is upon
those imposing the regimes to demonstrate that this is justified. ... To the best of my knowledge,
no convincing demonstration has yet been provided" (King, 2000, p. 182); "Supermaxes have to
justify or modify the draconian strictures that typically prevail at entry into the setting. The argument that such strictures are required as an incentive for promotion to a less sensorily-deprived
environment is specious because less onerous gradations of conditions would serve the same
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