and focused particularly on 23-and- 1 lockdown. 114 It found that the system still confined a
significant number of wards to cells for twenty-three hours per day. 115 Other youth received three
hours outside their cell but were forced to spend it in a “ 10’ x 16’ cyclone-fenced asphalt enclosure
with no recreation equipment or toilet facilities and only a small amount of water.” 116 Some youth
had been on administrative lockdown117 for more than thirty days and a few for more than two
hundred days. 118 The Inspector General made several specific follow-up recommendations for
In December 2005, the Inspector General released its review into the death of Joseph
Maldonado earlier that year. 120 The report found that an emergency institutional lockdown at N.A.
Chaderjian in connection with a gang-related attack on staff had initially been justified, but that
eight weeks in isolation and denial of mental health services may have contributed to Joseph’s
suicide. 121 The Inspector General was especially troubled that 23-and- 1 lockdown persisted despite
the Director’s previous statement that it ended. 122 The report called, again, for an end to 23-and- 1
and for significant changes in mental health interventions for youth at risk of self-harm. 123
G. The Farrell Remedial Plans on Lockdown Issues (2005)
Prison Law Office documented the ongoing failure to implement the changes set forth in
the Farrell consent decree and continued to pursue compliance. 124 In 2005, California’s
Department of Corrections released a Safety and Welfare Remedial Plan (the Plan). 125 It called for
the state to consult with nationally recognized experts to assist in the design, development, and
implementation of additional rehabilitation and treatment interventions in the areas of violence
reduction, gang integration, substance abuse and dependence, and normative culture, as well as
REVIEW OF AUDITS OF THE CALIFORNIA YOUTH AUTHORITY 2000-2003 (Jan. 2005),
114 Id. at 7–21.
115 Id. at 7.
116 Id. at 12.
117 The report defined “administrative lockdown” as “the restriction to cells of all wards in a living unit or a facility
due to an operational emergency that threatens the safety of wards or staff. Under department policy, administrative
lockdown is to continue only as long as necessary to restore the safe operation of the facility or living unit. Id. at 8.
118 Id at 111.
119 CATE, supra note 113, at 14–19.
120 MATTHEW L. CATE, INSPECTOR GENERAL, OFFICE OF THE INSPECTOR GENERAL, SPECIAL REVIEW INTO THE DEATH
OF A WARD ON AUGUST 31, 2005 AT THE N.A. CHADERJIAN YOUTH CORRECTIONAL FACILITY (Dec. 2005),
121 Id. at 1, 10–13.
122 Id. at 14.
123 Id. at 14, 15–29.
124 Stipulation Regarding California Youth Authority Remedial Efforts, Farrell v. Allen, Case No. RG 03079344 (Cal.
Sup. Ct. 2005), https://www.clearinghouse.net/chDocs/public/JI-CA-0013-0003.pdf.
125 CAL. DEP’T OF CORRECTIONS & REHABILITATION, DIV. OF JUV. JUST., REFORMING CALIFORNIA’S JUVENILE
CORRECTIONS SYSTEM: FARRELL V. HICKMAN, SAFETY & WELFARE REMEDIAL PLAN 2 (Nov. 30, 2005),
https://www.cdcr.ca.gov/Juvenile_Justice/docs/4_safety_welfare.pdf [hereinafter SAFETY &WELFARE REMEDIAL