rehabilitative processes is greater.28 Unlike the adult criminal justice system, the rehabilitative
process has been at the cornerstone of the juvenile justice system since its inception.29
Additionally, the United States Department of Justice, Office for Civil Rights recognized
that using isolation on juveniles as punishment has a more profound effect on youth than adults.30
The Office of Juvenile Justice and Delinquency Prevention stated that being subjected to isolation
“begins to damage the juvenile, cause resentment toward the staff, and serves little useful
purpose.”31 Courts also have recognized the harmful effects of placing youth in isolation. In
Inmates of Boy’s Training School v. Affleck, the court concluded that:
To confine a boy without exercise, always indoors, almost always in a small cell,
with little in the way of education or reading materials, and virtually no visitors
from the outside world, is to rot away the health of his body, mind, and spirit. To
then subject a boy to confinement in a dark and stripped confinement cell with
inadequate warmth and no human contact can only lead to his destruction.32
Further examination of the consequences of isolation practices with youth suggests that
isolation can increase symptoms in youth with existing mental illnesses, including agitation,
aggression, anger, and difficulties with concentration and thinking.33 For youth without
underlying mental illnesses, symptoms may occur as a result of isolation.34 The lack of positive
reinforcements and rehabilitative services, which often accompany isolation practices, further
exacerbate the negative consequences.
2. Isolation Can Exacerbate a Youth’s Underlying Mental Illness
Although only limited research exists regarding the negative effects resulting from
isolation on the mental stability of youth, studies on adults in solitary confinement demonstrate
that isolation “often result[s] in severe exacerbation of a previously existing mental condition.”35
Such measures have not only been shown to be an ineffective method of treatment,36 they can
also increase the likelihood of future delinquency or criminal activity.37 The harmful effects are
“especially significant for persons with serious mental illness,”38 as “stress, lack of meaningful
social contact, and unstructured days” can trigger or aggravate the symptoms of youth’s pre-
existing mental disorders.39
29 Id. at 286.
30 See Letter from R. Alexander Acosta, Assistant Att’y Gen., to Jennifer M. Granholm, Governor of Mich. 4 (Apr. 19, 2004)
[hereinafter Letter to Governor of Mich.], available at http://www.justice.gov/crt/about/spl/documents/granholm_findinglet.pdf
(“These lengthy isolations can have serious negative consequences for residents. Indeed, lengthy periods of isolation can be
psychologically damaging to youth, who generally experience time differently from adults. Youth may experience symptoms such as
paranoia, anxiety, and depression even after short periods of isolation.”) (emphasis added).
31 OFFICE OF JUVENILE JUSTICE & DELINQUENCY PREVENTION, STANDARDS FOR THE ADMINISTRATION OF JUVENILE JUSTICE 496
32 Inmates of Boys’ Training Sch. v. Affleck, 346 F. Supp. 1354, 1365-66 (D.R.I. 1972) (emphasis added).
33 Stuart Grassian, Psychiatric Effects of Solitary Confinement, 22 WASH. U. J.L. & POL'Y 325, 328-36 (2006).
35 Id. at 329. Research in this area is limited. Dr. Grassian is among a limited number of psychiatrists in the country that have
conducted extensive interviews with adults in isolation.
36 COAL. FOR JUVENILE JUSTICE, HANDLE WITH CARE: SERVING THE MENTAL HEALTH NEEDS OF YOUNG OFFENDERS 70 (2000).
37 Id. at 71. The report notes that interventions for youth who are mentally ill which focus on family rebuilding and intensive therapy
can reduce the changes of recidivism by eighty percent. Id. at iii.
38 Jeffrey L. Metzner & Jamie Fellner, Solitary Confinement and Mental Illness in U.S. Prisons: A Challenge for Medical Ethics, 38 J.
AM. ACAD. PSYCHIATRY & LAW 104, 104 (2010).
39 Id. at 105; see also Karen M. Abram et al., Posttraumatic Stress Disorder and Trauma in Youth in Juvenile Detention, 61 ARCH.
GEN. PSYCHIATRY 403, 408-09 (2004) (describing prevalence estimates of exposure to trauma and rates of posttraumatic stress
disorder (PTSD) among juvenile detainees).