Studies regarding the onset of psychological disease as a result of isolation practices have
primarily focused around adult inmates.91 This research indicates that isolation can cause severe
psychiatric harm, even when the individual had no history of mental illness prior to his or her
isolation.92 Dr. Grassian’s work documents the serious psychiatric pathology found in many of
the inmates housed in harsh conditions of solitary.93 These included an inability to tolerate
ordinary stimuli, auditory hallucinations of voices saying frightening things or bizarre noises,
panic attacks, severe difficulty with thinking, concentration and memory, intrusive obsessional
thoughts, primitive aggressive ruminations, and paranoid, persecutory fears.94
The research from this study described symptoms, which were not only dramatic, but also
not found in any other psychiatric illness.95 Dr. Grassian even suggested that the unique nature of
the symptoms appeared to form a “discreet syndrome.”96 Symptoms included “acute dissociative,
confusional psychoses,” and “extensive perceptual disturbances experienced by the isolated
person.”97 Additionally, loss of perceptual constancy, rarely found anywhere else, is generally
associated with neurological illness such as seizure disorders or brain tumors, rather than a
primary psychiatric illness.98
A number of studies have demonstrated that individuals vary significantly in “their
capacity to tolerate a given condition of sensory restriction.”99 Individuals of average intelligence
who have mature and healthy personality functioning can better tolerate the effects of isolation
without regression and perceptual disturbances.100 Even individuals with these stabilizing
attributes can “inevitably suffer severe psychological pain as a result of [isolation],” especially
where the isolation is prolonged or the punishment is perceived by the individual as arbitrary and
unjust.101 The prognosis for those without such stabilizing factors is far worse. “On the other
hand, individuals with primitive or psychopathic functioning or borderline cognitive capacities,
impulse-ridden individuals, and individuals whose internal emotional life is chaotic or fearful are
especially at risk for severe psychopathologic reactions to such isolation.”102 In either case,
however, the individual’s ability for successful re-integration back into the community may be
hampered by the prospect of permanent psychiatric disability caused by isolation.103
Dr. Grassian’s review of six youth in a special management unit in an Ohio juvenile
correctional facility reveals several startling examples of how such deterioration may manifest,
although in each case youth were previously diagnosed with some form of mental illness.104 After
reviewing the charts of the youth that were held in isolation for months, and in some cases years,
Dr. Grassian’s conclusion definitively notes the deterioration patterns found in each case:
91 Id. at 333; see, e.g., Craig Haney, “Infamous Punishment”: The Psychological Consequences of Isolation, 8 NAT’L PRISON PROJECT
J. 3, 4 (1993); Craig Haney & Mona Lynch, Regulating Prisons of the Future: A Psychological Analysis of Supermax and Solitary
Confinement, 23 N. Y.U. REV. L. & SOC. CHANGE 477, 484-85 (1997).
92 See, e.g., Grassian, supra note 33, at 333.
94 Id. at 335-36.
95 Id. at 337.
96 Id. Dr. Grassian defines a discreet syndrome as “a constellation of symptoms occurring together and with a characteristic course
over time, thus suggestive of a discrete illness.” Id.
97 Id. at 335, 337.
98 Id. at 337.
99 Id. at 347.