Brief of Amici Curiae Terry Kupers, Craig Haney, Pablo Stewart, and Stuart Grassian in Support of Plaintiff-Apellee and Affirmance
Marissa Lalli
Nina B. Garcia
Hannah E. Gelbort
William Cutler Pickering
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Summary

Solitary confinement can have significant psychological and physical harm on prisoners, particularly for those suffering from addiction or those forced to spend extended periods in isolation.

2023 | State Juristiction

Brief of Amici Curiae Terry Kupers, Craig Haney, Pablo Stewart, and Stuart Grassian in Support of Plaintiff-Apellee and Affirmance

Keywords solitary confinement; isolation; administrative segregation; substance use; trauma; psychological harm; physiological harm; penal confinement
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Summary of Argument

Amici Curiae are professors and practitioners of psychiatry and psychology with extensive experience studying the psychological and physiological effects of imprisonment and/or treating individuals who are in penal confinement, including solitary confinement. Based on their research and assessment of the professional literature, amici curiae have concluded that any amount of solitary confinement which deprives a prisoner of two basic human needs— social contact and adequate positive environmental stimulation—can cause grave damage to that prisoner’s mental and physical health. The damage can be exacerbated when the period of isolation is lengthy. Indeed, this damage has long been recognized by experts and society at large.

Psychologists and psychiatrists agree that solitary confinement can have disastrous psychological and physical consequences for prisoners who are confined to a small cell without meaningful social interaction or positive environmental stimulation. The dangerous effects of solitary confinement are particularly grievous for prisoners like Appellee Jerry Cintron, who suffer from opioid addiction and are forced to spend extended periods in solitary confinement.

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Summary of Argument

Amici curiae, experts in psychiatry and psychology, present evidence demonstrating the severe psychological and physiological consequences of solitary confinement, defined as the deprivation of social contact and environmental stimulation. The detrimental effects are exacerbated by prolonged isolation and are particularly harmful for individuals with pre-existing conditions such as opioid addiction.

Solitary confinement has been widely recognized as a practice that inflicts profound harm on prisoners' mental and physical well-being. Research and clinical experience have consistently shown that depriving individuals of basic human needs, such as social interaction and positive environmental stimulation, can lead to severe psychological distress, cognitive impairment, and physical deterioration.

Solitary confinement can cause a range of psychological problems, including anxiety, depression, hallucinations, and suicidal ideation. The lack of social contact can lead to feelings of isolation, loneliness, and despair. The absence of environmental stimulation can result in cognitive decline, difficulty concentrating, and memory problems.

Moreover, solitary confinement can exacerbate pre-existing mental health conditions, such as opioid addiction. The isolation and stress associated with solitary confinement can trigger cravings and withdrawal symptoms, making it extremely difficult for individuals to manage their addiction.

The evidence presented by amici curiae underscores the grave consequences of solitary confinement. Any amount of isolation that deprives prisoners of social contact and environmental stimulation can cause significant harm to their mental and physical health. The practice of solitary confinement should be reevaluated and limited to the most exceptional circumstances, with appropriate safeguards in place to mitigate its harmful effects.

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Summary of Argument

Experts in mental health have studied the effects of solitary confinement, where prisoners are isolated in small cells with little social contact or stimulation. They have found that this type of confinement can have serious consequences for prisoners' mental and physical health.

Solitary confinement can lead to a range of psychological problems, including anxiety, depression, hallucinations, and suicidal thoughts. It can also cause physical problems, such as high blood pressure, heart disease, and weakened immune systems.

The negative effects of solitary confinement are even worse for prisoners with certain conditions, such as opioid addiction. For example, Jerry Cintron, a prisoner who is addicted to opioids, has experienced severe psychological distress while in solitary confinement.

Experts agree that solitary confinement can have devastating consequences for prisoners' health. They emphasize that depriving prisoners of social contact and stimulation is harmful and should be avoided whenever possible.

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Summary of Argument

Experts in mental health say that solitary confinement can be really harmful to prisoners' minds and bodies. It can make them feel lonely, anxious, and depressed. It can also cause physical problems like trouble sleeping and headaches.

Prisoners with mental health problems or drug addictions are especially at risk of being harmed by solitary confinement. For example, people with opioid addiction, like Jerry Cintron, can suffer a lot if they are put in solitary confinement for a long time.

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Summary of Argument

Doctors who study the brain and body say that being alone in a small room, called "solitary confinement" in prison, for a long time can hurt people's minds and bodies.

Being in solitary confinement can make people feel very lonely, scared, and angry. It can also make them have trouble sleeping, thinking clearly, and controlling their emotions. It can even make them hallucinate, which means seeing or hearing things that aren't real.

For people who have problems with drugs, like a man named Jerry Cintron, being in solitary confinement can make their problems worse. It can make them more likely to use drugs again when they get out of jail.

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Footnotes and Citation

Cite

Brief for Amici Curiae Terry Kupers, Craig Haney, Pablo Stewart, and Stuart Grassian Supporting Plaintiff-Appellee, Cintron v. Bibeault, No. 22-1716 (1st Cir. May 10, 2023).

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