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Pennsylvania Prisoner Released from Solitary After 15 Years

On March 5, 2024, the federal court for the Western District of Pennsylvania agreed to dismiss the complaint of a state prisoner held in solitary confinement for 15 years after the state Department of Corrections (DOC) reportedly agreed to a settlement. Under its terms, Caine Pelzer, 45, returned to the general population of the State Correctional Institution (SCI) at Albion. The DOC also agreed to pay him $85,000, defraying his legal costs and fees tom secure release from isolation.

Ironically, SCI-Albion is the site of the DOC’s Neurodevelopmental Residential Treatment Unit (NRTU), established in March 2021 to help state prisoners with autism and intellectual disabilities avoid disciplinary infractions and punishment in solitary by teaching strategies to cope with stress or anger.

It came along too late for Pelzer, who was tossed in solitary confinement at the prison in March 2009. For the next 15 years, his world was a 91-square-foot cell—really 56 square feet clear of the toilet and other fixtures. During every 168-hour week, he was allowed out to exercise by himself in a 75-square-foot cage cell for just six hours.

Pelzer filed suit pro se in 2020, accusing DOC officials of violating his Eighth Amendment guarantee of freedom from cruel and unusual punishment. After securing counsel in 2021 from Erie attorney John F. Mizner, his case was headed to trial, when Defendants—tellingly—moved to prevent use of the words “solitary confinement” before jurors. That motion was shot down on February 27, 2024, and the following day, Defendants failed to prove that their grievance system was available to Pelzer. His non-exhaustion of those remedies was excused. The parties then proceeded to reach their settlement agreement. See: Pelzer v. Pa. Dep’t of Corr., 2024 U.S. Dist. LEXIS 37168 (W.D. Pa.); and 2024 U.S. Dist. LEXIS 34011 (W.D. Pa.).

The need for NRTU to protect prisoners like Pelzer was soon made strikingly clear, when Curtis Waugaman II, 56, was found unresponsive in his cell with a self-inflicted cut on March 20, 2024. He bled out at the prison infirmary, and his death was ruled a suicide.

The United States Bureau of Justice Statistics recognizes a 4% rate of autism among prisoners and a nearly 25% rate of cognitive impairments—twice the rate for each group in the overall population. Prison reform advocates believe the numbers are even higher because of underdiagnosis before incarceration and absent or ineffective screening in most prisons and jails.

Specialized units like NRTU focus on prisoner integration versus segregation, which is a key idea promoted by the Americans with Disabilities Act, 42 U.S.C. ch. 126 § 12101 et seq. Yet many prisoners with intellectual disabilities are isolated to protect them from harm—only to face further risks in solitary. “What we’ve seen is, after solitary, the ways they have learned to interact all reverse,” said Brian Kelmar of Decriminalize Developmental Disabilities.

NRTU utilizes “transitional cells,” prisoners regain self-control before rejoining their unit. Staffer Randy Kulesza called the cells a huge help, especially since placement in one does not threaten a prisoner’s chance for parole the way that placement in solitary would.  

Additional sources: AP News, Erie Times-News, Meadville Tribune

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