Arizona is one of the most significant solitary confinement cases in the country right now. A decade of litigation culminated in June 2022, when U.S. District Judge Roslyn Silver found that conditions in Arizona's Department of Corrections, Rehabilitation and Reentry (ADCRR) -- specifically its use of long-term isolation -- violated the Eighth Amendment's prohibition on cruel and unusual punishment. The April 2023 injunction that followed ordered sweeping changes, and ADCRR has made measurable progress: the population in "maximum custody" (Arizona's official term for long-term solitary) dropped from 1,071 people in January 2023 to roughly 200 by mid-2024 -- an 80-plus percent reduction. Arizona's original supermax facility was closed entirely in November 2023. But the litigation continues: in February 2025, the ACLU and the Prison Law Office filed a motion asking the court to appoint a receiver to oversee healthcare, citing continued constitutional violations. Arizona is a state where real reform has happened -- and where the fight isn't over.
What Solitary Confinement Is Called in Arizona
ADCRR uses two primary terms for isolation:
Maximum Custody: ADCRR's official term for long-term single-cell isolation. This is the status that was at the center of Jensen v. Thornell. At the time of the June 2022 court finding, ADCRR's own officials admitted there was "no penological justification" for keeping hundreds of people in maximum custody. The court described keeping people in maximum custody when there was no justification as a constitutional violation.
Restrictive Housing: ADCRR's current term for housing that results from current and ongoing institutional violence or conspiracy to commit violent acts -- serious assaults on staff, serious inmate-on-inmate assaults with a weapon, or multiple inmates assaulting an inmate with serious injury. Under ADCRR's definition, Restrictive Housing is meant to give people "an opportunity to modify their behavior in a positive way so they can safely return to the general population." The December 2024 Monthly Data Report reflects ADCRR's current use of this term.
Detention: Used for shorter-term separation pending disciplinary hearings or investigations. People in detention are held separately from general population while a decision is being made about their housing.
Who Gets Placed in Solitary in Arizona
Before the Jensen injunction, the court found that ADCRR kept "hundreds of prisoners in maximum custody housing despite all prison officials admitting there is no penological justification for doing so." This was a central finding in the constitutional violation ruling -- people were placed in long-term isolation not because it was necessary, but because the system lacked alternatives and accountability.
Under the Jensen injunction and current ADCRR policy, Restrictive Housing is supposed to be limited to people involved in current and ongoing institutional violence: serious assaults on staff, serious inmate-on-inmate assaults with a weapon, or multiple-inmate assaults causing serious injury. Administrative detention is used for people pending hearings.
Conditions in Arizona Solitary Confinement
Before the injunction, conditions in Arizona's maximum custody units were described in court findings as shocking. People received only two meals a day in some facilities (the injunction required three meals). Staffing was so inadequate that constitutionally required mental health care could not be provided. People remained in long-term isolation without documented justification. The court called out ADCRR's awareness of these failures and its refusal to take necessary corrective action.
Under the April 2023 injunction, ADCRR was required to:
- Ensure that no person is confined for 22 or more hours per day for more than two months without documented legitimate justification.
- Implement a system to move people in isolation to lower custody levels after two months.
- Increase staffing to prevent unjustified housing in solitary confinement.
- Ensure people in the relevant class have access to services.
- Comply with prohibitions on placing juveniles and Seriously Mentally Ill (SMI) individuals in 22-hours-per-day isolation.
ADCRR publishes monthly Jensen Injunction Progress Reports tracking compliance with these requirements. These reports are publicly available at corrections.az.gov.
How Long People Stay in Solitary
The April 2023 injunction established a critical rule: no person may be confined for 22 or more hours per day for more than two months without documented legitimate reasons. This two-month threshold, combined with a required system to move people to lower custody levels, was designed to break the pattern of indefinite long-term isolation that the court found unconstitutional.
Before the injunction, at least 200 of the 1,071 people in maximum custody had been there for a year or more, and six people had been there for over a decade. By April 2024, the maximum custody population had dropped to just over 200, and half of those who had been in maximum custody for over a decade were no longer in solitary.
The injunction's two-month rule does not mean someone must automatically be released from restrictive housing after two months -- it means that continued placement requires documented legitimate justification.
Due Process Before Placement
The Jensen injunction and ADCRR policy require documented justification for housing decisions. The process includes classification reviews and hearings. People moved to maximum custody or restrictive housing are entitled to notice and a review process before or shortly after placement.
ADCRR's four court-appointed neutral monitors review compliance with the injunction's requirements on an ongoing basis and report to the court.
Protections for Juveniles and Seriously Mentally Ill
The Jensen injunction contains specific, absolute prohibitions for two groups:
Juveniles (under 18): No person under 18 may be placed in confinement for 22 or more hours per day for any amount of time. This is a hard ban, not a time-limited restriction.
Seriously Mentally Ill (SMI): Within 60 days of the April 2023 order, ADCRR was required to stop housing anyone designated as SMI in solitary confinement for 22 hours a day for any amount of time. This too is an ongoing prohibition, not a time limit.
These two prohibitions are among the strongest protections in the injunction and represent a significant change from pre-2023 conditions, when the court found people with serious mental illnesses were routinely held in isolation.
What Progress Has Arizona Made
Arizona's progress under the Jensen injunction has been significant by the numbers:
Population reduction: The maximum custody population dropped from 1,071 in January 2023 to just over 200 by April 2024 -- more than 80% reduction.
Supermax closure: Arizona's original supermax facility, with a reported capacity of 2,440 (most held in solitary), was closed entirely in November 2023.
Meal access: People in solitary now receive three meals per day in most cases, compared to only two before the injunction.
Long-term isolation: Half the people who had been in maximum custody for over a decade were no longer in solitary by April 2024.
However, the litigation continues. The ACLU and Prison Law Office filed a motion in February 2025 asking Judge Silver to appoint a receiver to oversee healthcare in Arizona state prisons, citing continued constitutional violations after nearly 14 years of litigation. The ACLU stated: "After nearly 14 years of litigation with Defendants having not gained compliance, or even a semblance of compliance with the Injunction and the Constitution, this approach has not only failed completely, but, if continued, would be nothing short of judicial indulgence of deeply entrenched unconstitutional conduct." ADCRR Director Ryan Thornell has acknowledged "unprecedented" suicides and ongoing challenges.
ADCRR publishes monthly Jensen Injunction Progress Reports and Monthly Data Reports at corrections.az.gov for ongoing tracking.
What Families Can Do
If your person is in maximum custody, restrictive housing, or detention in an Arizona prison:
Find where your person is housed. ADCRR provides an inmate search tool at azinmatesearch.az.gov. This is the starting point.
Check the public monthly reports. ADCRR's Jensen Injunction Progress Reports and Monthly Data Reports are publicly available at corrections.az.gov. These reports track compliance with the injunction's requirements, including the number of people in restrictive housing and detention, and are an unusual level of public transparency.
Contact the facility. For visiting rules, communication access, and status information specific to your person's housing assignment, contact the facility directly. ADCRR facility contact information is at corrections.az.gov.
Understand communication restrictions. People in restrictive housing or detention in Arizona may have phone and visiting privileges restricted. Written mail generally has stronger protections. Legal mail is additionally protected.
File a grievance. The person in custody must typically exhaust ADCRR's administrative grievance process before filing in federal court. Help your person understand the process and track deadlines and responses.
Contact the ACLU National Prison Project and Prison Law Office. Both organizations are active counsel in Jensen v. Thornell and monitor ADCRR compliance. ACLU: aclu.org/cases/jensen-v-thornell. Prison Law Office: prisonlaw.com/jensen.
Contact Middle Ground Prison Reform. Donna Leone Hamm's organization (middlegroundprisonreform.org) monitors Arizona prison conditions and may be a local resource for referrals.
Contact Disability Rights Arizona. For people with disabilities, including serious mental illness, who are being held in solitary in potential violation of the SMI prohibition under the Jensen injunction, Disability Rights Arizona (disabilityrightsaz.org) may be a resource.
Seek legal help. If your person is designated SMI and is in solitary, or is under 18 and in 22-hours-per-day confinement, these situations may implicate the absolute prohibitions in the Jensen injunction. Consult a prisoner rights attorney.
Frequently asked questions
What is solitary confinement called in Arizona prisons?
ADCRR uses "maximum custody" as its term for long-term single-cell isolation and "restrictive housing" for isolation tied to current or ongoing institutional violence. "Detention" is used for shorter-term separation pending hearings or investigations. The court in Jensen v. Thornell identified maximum custody as Arizona's version of solitary confinement and found the conditions unconstitutional.
What is maximum custody in Arizona?
Maximum custody is ADCRR's official term for long-term single-cell isolation. At the time of the June 2022 court finding, 1,071 people were in maximum custody -- with ADCRR officials themselves admitting there was no penological justification for keeping hundreds of them there. The April 2023 injunction required ADCRR to dramatically reduce this population and establish documented justifications for continued placements. By April 2024, the number had dropped to just over 200.
Who can be placed in restrictive housing in Arizona?
Under current ADCRR policy, Restrictive Housing is for people involved in current and ongoing institutional violence: serious assaults on staff, serious inmate-on-inmate assaults with a weapon, or multiple-inmate assaults causing serious injury. Detention is used pending hearings. The Jensen injunction requires documented legitimate justification for any placement in 22-hours-per-day confinement lasting more than two months.
What are conditions like in Arizona solitary confinement?
Before the injunction, conditions included only two meals per day in some facilities, inadequate mental health care due to staffing shortages, and no documented justification for hundreds of maximum custody placements. Under the April 2023 injunction, ADCRR is required to: provide three meals per day, ensure documented justification for placements over two months, increase staffing, provide services access, and absolutely prohibit 22-hours-per-day confinement for juveniles and Seriously Mentally Ill individuals.
What does the Jensen v. Thornell injunction require?
The April 7, 2023 injunction (Jensen v. Thornell, CV-12-00601) requires: no 22-hours-per-day confinement for more than two months without documented justification; a system to move people to lower custody after two months; no 22-hours-per-day confinement for anyone under 18 for any duration; no 22-hours-per-day confinement for anyone designated Seriously Mentally Ill for any duration; increased staffing; and access to services. Four court-appointed monitors oversee compliance, and ADCRR publishes monthly reports.
How long can someone stay in solitary in Arizona?
The injunction requires that no one be confined for 22 or more hours per day for more than two months without documented legitimate reasons. Continued placement beyond two months requires documented justification and a system for review. This does not automatically end placement -- it requires the justification to be documented and reviewed.
Are mentally ill prisoners protected from solitary in AZ?
Yes -- the Jensen injunction contains an absolute prohibition. Within 60 days of the April 2023 order, ADCRR was required to stop housing anyone designated as Seriously Mentally Ill (SMI) in solitary confinement for 22 hours a day for any duration. This is an ongoing prohibition, not a time-limited rule. Before the injunction, the court found people with serious mental illnesses were routinely placed in long-term isolation.
What progress has Arizona made since the 2023 injunction?
Significant population reduction: maximum custody dropped from 1,071 (January 2023) to roughly 200 (April 2024), an 80%+ reduction. Arizona's original supermax was closed in November 2023. People in solitary now receive three meals daily rather than two. Half of those in maximum custody for over a decade were moved out. ADCRR publishes monthly compliance reports. However, the ACLU filed a motion in February 2025 for a court-appointed receiver over healthcare, citing continued constitutional violations after nearly 14 years of litigation.
Can families visit someone in Arizona restrictive housing?
Visiting privileges for people in restrictive housing or detention are typically restricted. Contact the specific facility directly to confirm current visiting status before traveling. ADCRR facility contact information is at corrections.az.gov. Written mail has stronger protections than phone or visits. Legal mail is additionally protected.
What can families do if someone is in AZ solitary?
Use the ADCRR inmate search at azinmatesearch.az.gov to find your person. Review ADCRR's public Jensen Injunction Progress Reports and Monthly Data Reports at corrections.az.gov for system-wide context. Contact the facility directly for specific information. Help your person file grievances through ADCRR's administrative process. Contact the ACLU National Prison Project (aclu.org/cases/jensen-v-thornell), Prison Law Office (prisonlaw.com/jensen), Middle Ground Prison Reform (middlegroundprisonreform.org), or Disability Rights Arizona (disabilityrightsaz.org). If your person is SMI or under 18 and in 22-hours-per-day confinement, the injunction's absolute prohibitions may apply -- consult a prisoner rights attorney. ---
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