ADHD or other mood disorders because of their inability to tolerate environments with such
restricted levels of stimulus.76 Research on ADHD and Anti-Social Personality Disorders
indicates that both disorders are characterized by an inability to tolerate restrictions in
environmental stimulation.77 Both disorders share traits of impulsivity and behavior that seeks
stimulation, as well as biological abnormalities in central nervous system functioning.78
Dr. Stuart Grassian,79 a national expert on the use of solitary confinement, notes the lack
of systematic investigation into the characteristics that might raise warning flags as to the
susceptibility of an individual in isolation to severe psychological reactions.80 Some medical
research, however, suggests that in psychiatric settings, patients “whose internal emotional life is
chaotic and impulse-ridden and individuals with central nervous system dysfunction may be
especially prone to psychopathological reactions to restricted environmental stimulation in a
variety of settings.”81 As Dr. Grassian concludes, these are the individuals that are most likely to
break the rules and to be subjected to increasingly severe punishments such as isolation and
solitary confinement.82
An expert report filed by Dr. Grassian in S.H. v. Stickrath83 included an extensive
examination of six youth files evaluating the effects of long-term isolation on youth in a special
management unit.84 One such youth was admitted at age fifteen and had ADHD.85 Although he
was originally described as “calm, polite, and not demonstrating any risk to himself or others,” he
was immediately placed in a long-term segregation unit.86 By the time Dr. Grassian evaluated his
file, the youth had been in the Special Management Unit (SMU) for over a year.87 Dr. Grassian
described the impact that isolation had on this child:
Inevitably, after a few months his mental state and behavior deteriorated … his
emotional reactivity, his ability to tolerate frustration, plummeted. On December
11, 2011 he was going to kill himself because he could not immediately get a
drink of water. He was desperate to get his cuff port opened.88
This extreme emotional response is an example of how those individuals who suffer from
ADHD and bipolar disorder are unable to tolerate the restricted environmental stimulation found
in an isolation unit.89 This intolerance may subsequently cause an increased susceptibility to
psychopathological reactions while in isolation.90
6. Isolation Can Create Mental Illness in Youth
76 Grassian, supra note 33, at 350.
77 Id.
78 Id.
79 Dr. Grassian is a Board Certified psychiatrist with “extensive experience in evaluating the mental health care afforded to adults and
adolescents in” prisons and juvenile facilities, and in particular, “evaluating the psychiatric effects of isolated confinement.”
Declaration: Psychiatric Report in S.H. v. Reed at 1, S.H. v. Stickrath, 251 F.R.D. 293 (S.D. Ohio 2008), (No. 2:04-CV-1206)
[hereinafter Grassian Declaration].
80 Id.
81 Id. at 350-51.
82 Id. at 351.
83 S.H. v Stickrath, 251 F.R.D. 293 (S.D. Ohio 2008). Note that S.H. v. Stickrath is now S.H. v. Reed.
84 See Grassian Declaration, supra note 79, at 24-32.
85 Id. at 24.
86 Id.
89 See Grassian, supra note 33, at 331-33 (discussing the extreme psychological effects of isolation and sensory deprivation on
individuals with preexisting vulnerabilities as compared to those with more stable personalities).
