handle.”63 Stressors, which are “environmental events or chronic conditions that objectively
threaten the physical and/or psychological health or well-being of individuals of a particular age
in a particular society,” have also been shown to aggravate symptoms of depression.64
Institutions that fail to screen and identify youth with a history of trauma risk further harm to the
child when isolation is used as a method of controlling behaviors.
4. Isolation Can Exacerbate the Symptoms of Depression
Depression is also a common problem among youth in juvenile facilities. A 2006 study
by the National Center for Mental Health and Juvenile Justice suggests that nearly one in five
youth in juvenile justice programs suffered from mood disorders, such as depression.65 Those
rates were even higher for females, where nearly thirty percent were diagnosed with mood
disorders, and fifty-six percent with anxiety disorders.66
As with PTSD, adolescent depression may manifest in ways that lead to the imposition of
isolation. Adolescents manifest depression through a combination of symptoms, including
depressed mood and feelings of hopelessness and helplessness.67 Research indicates that
irritability is another common characteristic of depression in young adults, and increases with the
severity of the depressive state. Adolescent depression can also create anger and hostility, which
“increases the likelihood that [depressed youth] will provoke angry responses from other youth
(and adults)” and may “increase the risk of altercations with other youth.”68 Based on the
author’s experience, these behaviors and attitudes may lead facility officials to respond to such
behaviors by placing the youth in isolation. Facility officials make this decision without regard to
the fact that “[w]hat might look first to be bad behaviour may be a symptom of a major mental
disorder that if left untreated can have significant . . . psychological consequences.”69
Research on adult inmates who “are prone to depression and have had past depressive
episodes will become very depressed while in isolated confinement.”70 Isolation has also been
shown to increase self-mutilation and suicide attempts in mentally ill prisoners,71 due to the fact
that it “undoubtedly worsens emotional state, hinders problem-solving and can increase the risk
for life-threatening behavior.”72 Facilities can utilize more effective means of behavior control in
lieu of isolation, particularly for youth with mental health disorders such as depression and
anxiety. Such measures are discussed later in the Article.73
5. Isolation Can Agitate Youth with Attention Deficit Hyperactive and Bipolar Mood
While studies show that in the general school population only two to ten percent of youth
have ADHD,74 anywhere from nineteen to forty-six percent of youth in the juvenile justice system
are identified as having ADHD.75 Isolation can also be especially damaging for youth who have
63 KUBAN, supra note 57, at 6.
64 Benjamin L. Hankin, Adolescent Depression: Description, Causes, and Interventions, 8 EPILEPSY & BEHAV. 102, 105 (2006).
65 SHUFELT & COCOZZA, supra note 43, at 2. The study on prevalence collected information from Louisiana, Texas, and Washington
from three different settings: community-based programs, juvenile detention centers, and secure residential treatment facilities. Id.
66 Id. at 4.
67 Marie Crowe et al., Characteristics of Adolescent Depression, 15 INT’L J. MENTAL HEALTH NURSING 10, 13, 15 (2006).
68 Thomas Grisso, Adolescent Offenders with Mental Disorders, FUTURE CHILDREN, Fall 2008, at 143, 145.
69 Crowe et al., supra note 67, at 16.
70 HUMAN RIGHTS WATCH, supra note 46, at 152 (quoting Dr. Terry Kupers on the impact of segregation on adult inmates).
71 Id. at 179.
72 Raymond Bonner, Rethinking Suicide Prevention and Manipulative Behavior in Corrections, JAIL SUICIDE/MENTAL HEALTH
UPDATE, Fall 2001, at 7, 7-8 (2001).
73 See infra Part IV.
74 ROBERT B. RUTHERFORD, JR. ET AL., supra note 45, at 18; see HUMAN RIGHTS WATCH, supra note 46, at 179 (quoting Raymond