October 2016

The Safe Alternatives to Segregation Initiative:
Findings and Recommendations for the
Oregon Department of Corrections
Allison Hastings, Elena Vanko, and Jessi LaChance

© 2016 Vera Institute of Justice. All rights reserved.
Additional copies can be obtained from the communications department of the Vera
Institute of Justice, 233 Broadway, 12th floor, New York, New York, 10279,
(212) 334-1300. An electronic version of this report is available for download on Vera’s web
site, www.vera.org.
Requests for additional information about this report should be directed to Allison Hastings
at the above address or to contactvera@vera.org.

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Executive Summary
In recent years, a diverse range of international and national bodies, advocates, policymakers,
the U.S. Department of Justice, and corrections practitioners have called for prisons and jails to
reform their use of segregation, also known as solitary confinement or restrictive housing.
Whether citing the potentially devastating psychological and physiological impacts of spending
23 hours per day alone in a cell the size of a parking space, the cost of operating such highly
restrictive environments, or the lack of conclusive evidence that segregation makes correctional
facilities safer, these voices agree that change and innovation are essential endeavors.
In 2015, with funding from the U.S. Department of Justice, Bureau of Justice Assistance, the
Vera Institute of Justice partnered with the Oregon Department of Corrections to help the
agency reduce its use of segregation. That assistance included conducting an assessment of
Oregon’s use of segregation and identifying opportunities for reform and innovation. This report
presents the findings and recommendations from Vera’s assessment, offering Oregon strategies
for safely reducing its use of segregation.1
Key Findings
Six of the 14 prisons run by the Oregon Department of Corrections hold the vast majority of
Oregon’s population in segregation.2 On April 1, 2015 (the snapshot date used by Vera to
describe the makeup of the population on a given day), the total population in Oregon’s prisons
was 14,934. 1,114 of these people were housed in some form of segregation on that date, which
represents 7.5 percent of the total prison population. Vera’s key findings not only touch on
Oregon’s use of different types of segregation—such as disciplinary and administrative
segregation—but also examine racial, ethnic, and gender disparities as well as the use of
segregation for people with mental health needs.
Disciplinary segregation is overused, overly long, and characterized by
isolating conditions.
Vera found that disciplinary segregation, which is imposed as a sanction for rule violations,
accounts for the majority of Oregon’s use of segregation: 63 percent (702 people) of people in
segregation on April 1, 2015 were living in disciplinary segregation, and 90 percent of adults
overall who had contact with some type of segregated housing entered through these units. Vera
also found that people often cycle through disciplinary segregation for nonviolent rule
violations; in fact, the top rule violation resulting in a disciplinary segregation sanction was
disobedience of an order. Further, people can stay in disciplinary segregation for long periods of
1

For a summary of Vera’s recommendations, see Appendix 2.
For an overview of Oregon’s 14 state prisons and a list of segregation units within the six facilities
that were the focus of Vera’s assessment, see Appendix 1.
2

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time—up to six months—and conditions in these units are marked by extreme isolation, idleness,
and sensory deprivation.
Stays in administrative segregation can be long, isolating, and
unproductive for adults in custody.
Oregon also has multiple units and processes for housing people in administrative segregation, a
type of housing used for people whose notoriety, actions, or threats jeopardize institutional
safety. These units vary in terms of average length of stay, reasons for placement, and
availability of programming, with most people being housed in intensive management units.
One of the goals of intensive management units is to provide cognitive behavioral programming
to these men and women, so they can successfully transition back to general population or
community settings. However, at the time of Vera’s assessment, the only programs available to
people in these units were packet-based programs, which individuals were expected to complete
alone in their cells. Vera also found that people who had contact with these units tended to
spend over a year total in some form of segregation.
People of color and people with mental health needs are over-represented
in segregation.
Echoing trends identified by researchers regarding America’s use of incarceration overall,
African-American and Latino adults are over-represented in Oregon’s segregation units. People
of color comprise 26 percent of the total prison population, but 34.3 percent of its segregated
population. Similarly, people with mental health needs are over-represented in disciplinary
segregation, and women with significant mental health needs are overrepresented in all types of
segregated housing. On Vera’s snapshot date of April 1, 2015, 53 percent of the total female
population was designated as having significant mental health needs, while 84 percent of the
women in segregated housing had that designation.

Key Recommendations
The Oregon Department of Corrections is a progressive agency that has a well-documented
commitment to reform and dedication to staff safety and wellness. Vera acknowledges its many
innovations and reform efforts, but also sees room for improvement and offers
recommendations in this report that, if implemented, would further Oregon’s reputation as a
leader in corrections. Some of the key recommendations include:
§ Reducing the number of disciplinary infractions eligible for segregation sanctions and
reducing the maximum length of stay in disciplinary segregation;
§ Strengthening informal mechanisms and alternative responses for responding to lowlevel infractions without using segregation;

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§
§
§
§
§
§
§

Enhancing supports, structured activities, and programming in the general prison
population, to help keep people from going into disciplinary segregation;
Improving conditions of confinement in all segregated housing units;
Implementing instructor-led, out-of-cell programming in intensive management units;
Creating structured reentry processes for adults in custody transitioning out of long-term
segregation, so no one is ever released directly to the community from segregation;
Prohibiting placing adults in custody with serious mental illness, severe developmental
disability, or neurodegenerative diseases in any form of extremely isolating segregation;
Creating a committee to study and address disproportionate minority contact with
segregated housing; and
Increasing training for all staff on mental health issues, crisis response, communication,
and responding to gender differences and gender identity.

As the Oregon Department of Corrections moves forward with implementation of reform
efforts, Vera has every confidence that the agency will learn from its peers in the field, capitalize
on its own strengths, and use these recommendations as a springboard for improving the lives of
the men and women who live and work in Oregon’s prisons.

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Table of Contents
I. Background ........................................................................................................ 7
II. Vera’s Assessment Process ............................................................................. 10
III. Overview of the Oregon Department of Corrections ...................................... 12
Commitment to Reform .................................................................................... 12
Special Housing ................................................................................................ 12
IV. Findings and Recommendations ..................................................................... 17
A. Disciplinary Segregation ............................................................................... 18
Findings .......................................................................................................... 18
Recommendations ............................................................................................ 27
B. Administrative Segregation .......................................................................... 37
Findings .......................................................................................................... 37
Recommendations ............................................................................................ 42
C. Mental Health ............................................................................................... 48
Findings .......................................................................................................... 48
Recommendations ............................................................................................ 53
D. Racial and Ethnic Disparities ........................................................................ 56
Findings .......................................................................................................... 56
Recommendations ............................................................................................ 58
E. Women ......................................................................................................... 59
Findings .......................................................................................................... 59
Recommendations ............................................................................................ 60
F. Death Row .................................................................................................... 61
Finding ............................................................................................................ 61
Recommendation .............................................................................................. 61
G. System-wide ................................................................................................ 62
Findings .......................................................................................................... 62
Recommendations ............................................................................................ 63
V. Conclusion ....................................................................................................... 67
Appendix 1: Overview of Oregon Department of Corrections ............................... 68
Appendix 2: Summary of Recommendations ........................................................ 73

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I. Background
An extensive body of research in psychiatry, neuroscience, epidemiology, and anthropology,
spanning more than 150 years, has documented the detrimental impacts of segregation, also
known as solitary confinement or restrictive housing, on an individual’s health. This body of
evidence confirms what is perhaps understood intuitively—that prolonged isolation which
deprives a human being of social interaction and meaningful sensory stimulation results in
physical and psychological suffering. The combination of social isolation, sensory deprivation,
and enforced idleness is a toxic exposure that results in distinctive psychiatric symptoms,
including anxiety, depression, anger, difficulties with impulse control, paranoia, visual and
auditory hallucinations, cognitive disturbances, obsessive thoughts, hypersensitivity to stimuli,
post-traumatic stress disorder, self-harm, suicide, or psychosis.3 Segregation is also harmful to
physical health. The World Health Organization has noted that its effects can include
“gastrointestinal and genitourinary problems, diaphoresis, insomnia, deterioration of eyesight,
profound fatigue, heart palpitations, migraines, back and joint pain, weight loss, diarrhea, and
aggravation of preexisting medical problems.”4 Such effects can persist after release from
segregation, making it difficult to transition to life in the prison’s general population and in the
community.
As these negative impacts have come to light, concern about the overuse of segregation has
grown. The conditions to which people in segregated housing are subjected are now regularly
exposed by mainstream journalists and media outlets; and advocacy organizations, such as the
American Civil Liberties Union and the National Religious Campaign Against Torture, have
begun to mount more high-profile campaigns against its use.5 In response, policymakers and
corrections officials have begun to examine correctional segregation practices and call for
reform. In 2013 and 2016 respectively, the Association of State Correctional Administrators and

3

Stuart Grassian, “Psychiatric effects of solitary confinement,” Washington University Journal of Law &
Policy 22 (2006): 325; Craig Haney, “Mental health issues in long-term solitary and ‘supermax’
confinement,” Crime & Delinquency 49, no. 1 (2003): 124-156; Peter Scharff Smith, “The effects of
solitary confinement on prison inmates: A brief history and review of the literature,” Crime and
Justice 34, no. 1 (2006): 441-528; Stuart Grassian and Nancy Friedman, (1986) “Effects of sensory
deprivation in psychiatric seclusion and solitary confinement,” International Journal of Law and
Psychiatry 8, no. 1(1986): 49-65; Paul Gendreau, N.L. Freedman, G.J. Wilde, and G.D. Scott,
“Changes in EEG alpha frequency and evoked response latency during solitary confinement,” Journal
of Abnormal Psychology 79, no. (1) (1972): 54; Fatos Kaba et al., “Solitary confinement and risk of
self-harm among jail inmates,” American Journal of Public Health 104, no. 3 (2014): 442-447.
4
Lars Moller et al., eds., Health in Prisons: A WHO Guide to the Essentials in Prison Health
(Copenhagen: World Health Organization, 2007), p. 36.
5
To view recent work by such organizations, see: https://www.aclu.org/issues/prisonersrights/solitary-confinement; http://solitarywatch.com/; and
https://www.themarshallproject.org/?ref=nav#.MIjJlTEOC (all accessed October 24, 2016).

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the American Correctional Association passed new standards and principles regarding the use of
segregation.6 In 2016, a number of additional developments indicate further support for reform:
§
§

§

The National Commission on Correctional Health Care issued a strong position
7
statement calling for the elimination of isolation greater than 15 consecutive days;
The U.S. Department of Justice (DOJ) published a report that called for widespread
reform of restrictive housing practices in the Federal Bureau of Prisons and included a
number of guiding principles for reform that are applicable to state and local
8
correctional systems; and
The National Institute of Justice (NIJ) issued a report—a meta-analysis of empirical
research on administrative segregation—that seriously questions whether segregation
achieves any stated or intended penological goals, and whether it is worthwhile
9
correctional policy.

On the international level, in 2015, the United Nations General Assembly unanimously
adopted the revised Standard Minimum Rules for the Treatment of Prisoners (known as the
“Nelson Mandela Rules”), which prohibit indefinite solitary confinement and prolonged solitary
confinement and support restrictions on the use of solitary confinement for juveniles, pregnant
women, and people with mental or physical disabilities.10 Although non-binding, the Mandela

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In August 2016, the Standards Committee of the American Correctional Association (ACA) voted to
pass restrictive housing standards. In 2012, the Association of State Correctional Administrators
(ASCA) teamed up with the Arthur Liman Public Interest Program at Yale Law School to survey
directors of federal and state correctional systems on their policies regarding administrative
segregation. The results of that survey were published in 2013 in the report Administrative
Segregation, Degrees of Isolation, and Incarceration: A National Overview of State and Federal
Correctional Policies (New Haven, CT: Yale Law School) and updated in 2015 with Time-in-Cell: The
Liman-ASCA 2014 National Survey of Administrative Segregation in Prison (New Haven, CT: Yale Law
School). Additionally, in 2013, ASCA issued Restrictive Housing Status Policy Guidelines, available at
http://www.asca.net/system/assets/attachments/6145/B.%20ASCA%20Restrictive%20Status%20Hou
sing%20Policy%20Guidelines-Final%2008092013.pdf?1375723019 (accessed October 24, 2016).
7
National Commission on Correctional Health Care, “Position Statement: Solitary Confinement
(Isolation),” http://www.ncchc.org/filebin/Positions/Solitary-Confinement-Isolation.pdf (accessed June
28, 2016).
8
U.S. Department of Justice (DOJ), Report and Recommendations Concerning the Use of Restrictive
Housing: Final Report (Washington, DC: U.S. Department of Justice, January 2016); and Natasha
Frost and Carlos E. Monteiro, Administrative Segregation in U.S. Prisons (Washington, DC: U.S.
Department of Justice, National Institute of Justice, March 2016).
9
Frost and Monteiro, 2016, p.23.
10
“Prolonged solitary confinement” is defined as the confinement of prisoners for 22 hours or more a
day without meaningful human contact for a period longer than 15 consecutive days. United Nations
Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules), General
Assembly Resolution 70/175, U.N. Doc. A/Res/70/175 (2015), Rules 43-45. Two U.S. corrections
officials, and members of Vera’s Safe Alternatives to Segregation Initiative Advisory Council, were
involved in the drafting of the rules.

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Rules represent already widely accepted international principles on the treatment of
incarcerated people.11
Against this backdrop, several jurisdictions have already implemented policy changes to
reduce the number of adults or juveniles held in segregated housing, improve the conditions in
segregation units, or facilitate the return of segregated people to a prison’s general population.12
Two states of note—New York and California—enacted their reforms as part of legal settlements
to challenges to their use of, and conditions in, segregated housing. In a historic move, New
York now precludes certain categories of people from being placed into segregated housing—
pregnant women, most adults with developmental disabilities, and incarcerated people 17 and
under—and limits the circumstances in which segregation can be used as punishment.13
California’s settlement, among other things, ends its status-based system that sent affiliated
gang members to segregation based on affiliation alone, regardless of whether they had violated
a prison rule.14
It was in this context that the Vera Institute of Justice (Vera), with funding from the U.S.
Department of Justice Bureau of Justice Assistance, launched the Safe Alternatives to
Segregation Initiative in 2015. It was through this initiative that Vera partnered with Oregon
Department of Corrections (ODOC) to assess ODOC’s segregation policies and practices, analyze
outcomes of that use, and provide recommendations for safely reducing the use of segregation
and enhancing the use of alternative strategies.

11
These international human rights norms regarding the use of solitary confinement have been further
supported by the UN Committee Against Torture, the UN Special Rapporteur on Torture, and the UN
General Assembly. See United Nations Committee against Torture, Concluding observations on the
third to fifth periodic reports of United States of America, U.N. Doc. CAT/C/USA/CO/3-5 (November 20,
2014); Interim report of the Special Rapporteur of the Human Rights Council on torture and other
cruel, inhuman or degrading treatment or punishment, Juan E. Méndez, U.N. Doc. A/66/268 (August 5,
2011); and United Nations General Assembly, Resolution 68/156: Torture and other cruel, inhuman or
degrading treatment or punishment, U.N. Doc. A/RES/68/156 (December 18, 2013).
12
See DOJ, 2016, pp. 74-78 for descriptions of states and counties that have proactively sought to
reform their segregation practices, including Colorado, Washington, New Mexico, Virginia, and
Hampden County, Massachusetts.
13
See Peoples v. Annucci, 2016 U.S. Dist. LEXIS 43556 (S.D.N.Y., Mar. 31, 2016).
14
See Ashker v. Governor of California, Settlement Agreement C 09-05796 CW (N.D. California, 2015).

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II. Vera’s Assessment Process
In partnership with the Oregon Department of Corrections (ODOC), Vera conducted an
assessment of Oregon’s use of segregation in state prison facilities between May 2015 and May
2016. Vera worked closely with ODOC’s designated site coordinator, Captain Joseph Etter,
throughout the assessment. The assessment included the following three main components:
analysis of administrative data; review of ODOC policies; and site visits to select facilities.
Administrative data analysis: Vera requested and was provided with location and
movement data as well as misconduct data for an 18-month period. After cleaning and
compiling the data, Vera researchers completed an analysis of the entire 18-month period
(January 1, 2014-July 22, 2015) and a “snapshot” analysis for one day (April 1, 2015). Using both
approaches enabled the assessment team to understand how people move through the system
over a period of time as well as the makeup of the population on a given day.
Policy review: The assessment team reviewed numerous ODOC policies, including but not
limited to policies regarding segregation practices, prohibited conduct and sanctions, alternative
sanctions, medical and mental health services, programs, and visiting.
Site visits: Vera’s assessment consisted of intensive site visits where the assessment team had
the opportunity to see policies in action and learn about practices on the ground. The
assessment team visited ODOC’s five medium-security facilities and one maximum-security
facility, where the vast majority of the segregated population is concentrated:
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§
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Oregon State Penitentiary (OSP) (maximum security)
Oregon State Correctional Institution (OSCI)
Coffee Creek Correctional Facility (CCCF) (women’s facility)
Snake River Correctional Institution (SRCI)
Two Rivers Correctional Institution (TRCI)
Eastern Oregon Correctional Institution (EOCI)

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At each facility, Vera completed a tour and conducted an informational meeting with the
facility superintendent and leaders, corrections officers, hearings officers, correctional
counselors, other security personnel, mental health staff, and program staff. These meetings
allowed the assessment team to learn how segregation is used at each facility and the range of
services provided for segregated populations. Through these tours and meetings, the team also
gained an understanding of disciplinary practices, decision points for segregation placement,
how and when alternative sanctions are used, procedures for placement in administrative
segregation, and practices for review and release to the general prison population or community.
The meetings also gave facility administrators and staff an opportunity to share their strengths
and challenges in general, as well as those related specifically to ODOC’s use of segregation.
The assessment team also conducted focus groups with staff assigned to segregated housing
and with adults in custody in order to better understand the experiences and perspectives of
staff and incarcerated people who had spent time working and living in these units. The team
was particularly interested in how the adults in custody viewed procedural fairness regarding
segregation practices.

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III. Overview of the Oregon Department of Corrections
Commitment to Reform
Vera’s partnership with ODOC was exceptionally collaborative and productive, thanks in large
part to the commitment and engagement of Director Colette Peters and ODOC’s designated site
coordinator for the project, Captain Joseph Etter. Additionally, as a system, ODOC has
consistently demonstrated commitment to reform and improvement, as evidenced by their
application to this project and other ongoing initiatives including their participation in the
Governor’s Re-entry Council, which works to reduce barriers for people transitioning from
prison to the community, and their adherence to Correctional Outcomes through Research and
Engagement (CORE), an evidence-based performance measurement system. ODOC has also
been a leader in compliance with DOJ’s National Standards to Prevent, Detect, and Respond to
Prison Rape (PREA standards) under the Prison Rape Elimination Act (PREA).
Vera identified a number of other strengths during the course of the assessment that will
likely serve ODOC well as it embarks on segregation reform. First, ODOC leaders and staff value
interdisciplinary collaboration. ODOC uses a number of multi-disciplinary committees and
processes that reflect a high level of collaboration among medical, mental health, security, and
administrative staff. This demonstrates an understanding among staff that the effective and
appropriate use of segregation is a shared responsibility, and it also suggests good staff
communication. Second, ODOC is committed to staff safety and improving staff wellness.
Among other initiatives, ODOC is working with Portland State University on a study of posttraumatic stress disorder among corrections staff, and Captain Garry Russell at CCCF told Vera
staff about an orientation initiative he has launched to help families of new corrections officers
understand the challenges and stresses of the job. Lastly, ODOC leaders recognize that security
staff and correctional counselors are instrumental in developing meaningful incentives and
productive activities for adults in segregation, and therefore nurture their ideas. During the
course of the assessment, Vera learned about various staff-led efforts and reforms to segregation.
These include piloting packet-based cognitive behavioral programming in disciplinary
segregation, implementing a phone call incentive program, and developing the Blue Room, a
converted indoor recreation room in the intensive management unit at Snake River Correctional
Institution where nature images and sounds are projected on the wall to have a soothing effect
on adults in custody with serious mental health issues (the Blue Room is discussed in greater
detail in Section IV.B).

Special Housing
In Oregon, the term “special housing” is used to denote housing units that are separate and
distinct from general population. Special housing encompasses units that confine adults in
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custody to cells for 22-24 hours a day with limited human interaction and little or no access to
constructive activity. However, it also denotes units where adults in custody have significant
out-of-cell time and opportunities to congregate with other incarcerated people. These include
units that provide intensive treatment services, protection from threats in general population,
and housing for adults in custody on death row status. Although Vera’s assessment focused
primarily on the highly restrictive units, descriptions of the less restrictive special housing units
are included below to highlight the ways in which ODOC has already succeeded in reducing
isolation for some of its special populations.
Descriptions of temporary holding cells used to segregate people at intake at CCCF are not
included in the overall analysis. These cells are not considered “special housing” in the same way
as units listed below, since they are designed for short-term (14 days or less) holding.15 However,
because the conditions in these cells are highly restrictive, we do include contact with these cells
in a couple of our overarching findings in Section IV.
1. Disciplinary Segregation Unit (DSU)
Adults in custody who violate the rules of prohibited conduct, who are under investigation, who
request or require immediate short-term protective custody, or who require short-term close
observation for risk of self-harm can be placed in disciplinary segregation. Adults who require
protective custody or close observation for risk of self-harm are generally only in DSU for the
shortest time possible before being placed in a more appropriate setting. Those in DSU for a rule
violation can stay there for up to 10 days before a disciplinary hearing is scheduled and can be
sanctioned to DSU for a violation of a major rule for up to 120-180 days. Adults who are in DSU
pending administrative segregation placements, referred to as “administrative hold” or “ad hold,”
can be in DSU for up to 30 days before a hearing takes place.
All six facilities that were the focus of Vera’s site visits operate a DSU.
2. Intensive Management Unit (IMU)
IMU is designated for adults in custody whose classification score indicates they should be
housed in custody Level 5 (ODOC’s highest custody level) and who demonstrate behaviors that
are difficult to control in general population because of their high severity. These behaviors can
include chronic rule violations, escape activity, or security threat group activity. An adult in
custody whose behavior poses significant management challenges may be referred for IMU
placement by a special interdisciplinary committee called the Special Needs Inmate Evaluation
Committee (SNIEC) to the Office of Population Management (OPM), a central ODOC office. The
Special Population Management (SPM) Committee, chaired by OPM, considers the request and
15
Staff may use these cells for a few different purposes. For example, someone who is returning to
ODOC custody and who did not complete a sanction in disciplinary segregation or a stay in
administrative segregation during his or her previous sentence would be housed in one of these cells
before being sent on to a different prison. Staff may also use one of these cells to hold an adult in
custody whose threatening or violent behavior is causing disruptions at intake.

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determines whether the adult in custody should go to IMU. An adult in custody placed in IMU
will typically be there for a minimum of 5½ months in order to complete required programming,
with the possibility for review 150 days after initial placement and then at 90-day intervals.
IMUs are located at SRCI and CCCF.
3. Behavioral Health Unit (BHU)
The BHU is an intensive behavioral management and skills training unit for adults in custody
who have serious mental illness (SMI) and score at custody Level 5 or who have been placed in
administrative segregation housing (usually IMU). If an adult in custody with SMI is referred to
IMU for rule violations, Behavioral Health Services (BHS) works with the SPM Committee at
OPM to place him or her in the BHU. An adult in custody placed in BHU is monitored by the
BHU Treatment Team, which may consist of qualified mental health providers (QMHPs), BHS
and unit security managers, unit security staff, correctional counselors, administrators, and
medical practitioners. To be released from the BHU, an adult in custody must progress through
a three-level system that uses dialectical behavioral therapy as the primary treatment model.16
The BHU Treatment Team determines when an individual is ready to be discharged from BHU.
BHUs are located at OSP and CCCF.
4. Administrative Segregation Unit (ASU)
Adults in custody whose notoriety, actions, or threats jeopardize institutional safety may be
placed in ASU. In ASU, individuals have property in their cells like general population, but are
only out of their cells one hour a day for recreation and twenty minutes a day for showers.
Admission to ASU can be voluntary or involuntary. Involuntary admission to ASU is decided by
the Hearings Office and requires additional layers of review and oversight. The SNIEC
completes status reviews every 30 days, and the Hearings Office conducts reviews every 180
days.
ASUs are located at SRCI and CCCF.
5. Administrative Housing Unit (AHU)
Adults in custody who have safety concerns and require protective custody may be placed in
AHU. Admission to AHU can be voluntary or involuntary. The involuntary admission process
for AHU follows the same hearings process and review procedures as described above for
involuntary admission to ASU. However, unlike ASU, AHU is a self-contained unit that operates
like a general population unit. Adults in custody in AHU are out of their cells most of the day.
The AHU is located at TRCI.
16
Dialectical behavioral therapy is a treatment model based on cognitive behavioral therapy that was
first used to treat people with borderline personality disorder, but which is now used to treat multiple
mental illnesses. It emphasizes accepting uncomfortable thoughts, feelings, and behaviors, and
working with a therapist on a plan for recovery. For more information, see
http://www.nami.org/Learn-More/Treatment/Psychotherapy (accessed September 19, 2016).

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6. Death Row
Adults in custody who have been sentenced to death live on death row. Adults in custody on
death row status are segregated from the general population in that they live in designated
special housing units. They are not isolated in their cells for 23 hours a day, but do receive less
out-of-cell time than the general population—about 25-30 hours per week. Services and
privileges on death row mirror those in general population to the extent possible. Some adults in
custody have jobs on the tiers, go outside for recreation twice a day in small groups, and have
dayroom time in small groups as well.
Death rows are located at OSP and CCCF.
7. Mental Health Infirmary (MHI)
The MHI is a crisis response unit that provides short-term psychiatric crisis stabilization,
evaluation, and medication adjustment. It essentially functions as the inpatient psychiatric
hospital in the prison system. Admission can be voluntary or involuntary; involuntary
admissions require a hearings process. The MHI operates a four-level system, allowing
progressively more property and out-of-cell time. When people first come to MHI, they are
isolated; however, by the time they get to Level 4, ODOC reports that they spend 4-8 hours out
of their cells per day. The MHI Treatment Team meets at least every 30 days to discuss
individuals’ treatment, progress through the levels, and pending discharges. Adults in custody
stay in MHI for as long as the MHI Treatment Team deems necessary.
MHIs are located at OSP and CCCF.
8. Intermediate Care Housing (ICH)
The ICH is a mental health special housing unit that provides stabilization for adults in custody
who require transitional care from the MHI or BHU to a lower level of mental health care, or
those who are unable to effectively manage their symptoms in general population and need
increased observation and care. Admissions can be voluntary or involuntary; individuals
involuntarily placed in this unit go through a hearings process. Once in ICH, they are reviewed
by the ICH Treatment Team every 30 days or as clinically indicated. Adults in custody are not
isolated in ICH. According to ODOC staff, they spend about 6-8 hours out of their cells per day.
They receive group and individual counseling, with daily to weekly contact with mental health
providers, as needed.
The ICH is located at OSP.
The Vera project mostly focused on Oregon’s use of DSU, IMU, BHU, and ASU. However,
because ODOC entered into a memorandum of understanding with Disability Rights Oregon
(DRO) in January 2016 to improve conditions and mental health treatment services for adults in
custody housed in the BHU, Vera offers limited recommendations to supplement the reform

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efforts already underway.17 ODOC is working with DRO to create more treatment space and
devise policies that allow significantly more out-of-cell time for adults in custody in the BHU.
Additionally, Vera provides limited findings and recommendations pertaining to AHU and
death row, which acknowledge and support ODOC’s practice of allowing congregate activity and
significant out-of-cell time in these units. MHI and ICH are not generally included, since they
are treatment units and adults in custody assigned to ICH are not isolated. Because MHI can be
isolating for individuals initially, it is included and referenced in some of the data analysis.

17

ODOC and DRO entered into a memorandum of understanding (MOU) in January 2016 following
DRO’s investigation into the conditions of the BHU at the Oregon State Penitentiary and subsequent
publication in 2015 of Behind the Eleventh Door: Solitary Confinement of Individuals with Mental
Illness in Oregon’s State Penitentiary Behavioral Health Unit, which is available at:
https://droregon.org/bhu/; the MOU is available at: http://disabilityrightsoregon.us3.listmanage1.com/track/click?u=df75f5fb9cfd9d242e8e630d9&id=f21e43edf3&e=4c7f2ace05 (both sites
accessed October 24, 2016).

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IV. Findings and Recommendations
ODOC oversees the operations and policies of 14 state prisons and two state-run county
community corrections offices. ODOC supervises over 14,600 adults in custody with a staff of
approximately 4,600 and a budget of $1.4 billion. Of the prison facilities, six facilities—Oregon
State Penitentiary (OSP), Oregon State Correctional Institution (OSCI), Coffee Creek
Correctional Facility (CCCF), Snake River Correctional Institution (SRCI), Two Rivers
Correctional Institution (TRCI), and Eastern Oregon Correctional Institution (EOCI)—hold the
vast majority of ODOC’s population in administrative or disciplinary segregation.18
On April 1, 2015, the total population in Oregon’s prisons was 14,934. The number of people
housed in some form of segregation on that date was 1,114.19 This represents 7.5 percent of
ODOC’s total population and breaks down in the following ways:

Figure 1. Segregated Housing Population by Unit
Death Row
3.1%

ASU SHU
2% 1.5%

Intake
0.6%

BHU
3.5%

AHU
6.8%

IMU
19.4%

18

DSU
63%

For an overview of Oregon’s 14 state prisons and a list of segregation units within the six facilities
that were the focus of Vera’s assessment, see Appendix 1.
19
Vera researchers did not include Death Row in the data analysis of ODOC’s use of segregation, but
we include the snapshot population number here to present a full picture of the population in some
form of segregation on April 1, 2015. Additionally, in the pie chart, “SHU” refers to the Special
Housing Unit at CCCF, where women assigned to DSU, IMU, BHU, or ASU are housed.

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Below Vera presents detailed findings and recommendations based on an assessment of
ODOC’s use of segregation. The first two sections focus on disciplinary segregation and types of
administrative segregation, respectively. Sections C through F address special populations—
people with mental health needs, racial and ethnic minorities, women, and adults in custody on
death row status. The final section provides system-wide findings and recommendations.

A. Disciplinary Segregation
Oregon’s use of disciplinary segregation was a central focus of the project because disciplinary
segregation accounts for the majority of the segregated population. In Oregon, disciplinary
segregation is used as a sanction for people who have gone through a hearings process and been
found guilty of an infraction. Disciplinary segregation units (DSUs) are also used for pre-hearing
segregation for both disciplinary and administrative reasons. A person can be placed in a DSU

on temporary status, pending the completion of a disciplinary report and investigation. An adult
in custody can also go to DSU on administrative hold status until a hearing has been completed
to determine whether placement in ASU or AHU is appropriate. Although this section refers at
times to adults in custody with mental health needs, Vera’s findings and recommendations
regarding the use of DSU for people with mental health needs appear in Section C. Mental
Health.
Findings
Finding A1. The majority of adults in custody living in segregated housing in
Oregon are in DSU. Based on Vera’s analysis of the snapshot data obtained for April 1, 2015,
1,114 adults in custody were in some form of segregated housing. Of those, 702 (63 percent)
were in DSU.
Finding A2. Approximately 90 percent of adults in custody who have contact with
segregated housing enter segregation through DSU. Because DSUs are used for those

serving disciplinary segregation sanctions as well as those on temporary disciplinary status or
administrative hold status, many people’s first contact with segregation is in a DSU. Some then
return to general population, while others are later moved to another form of segregation such as
IMU or ASU.

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Figure 2 below shows the number of people entering segregation during the 18-month period, by
their first segregated housing unit type. In this graph, “SHU” refers to the Special Housing Unit
at CCCF where women assigned to DSU, IMU, BHU, or ASU are housed.

Figure 2. Initial Contact with Segregated Housing

Number of People

6,967
6,000
4,000
2,000
26

6

84

14

173

226

366

0

Finding A3. DSU is frequently used as a sanction for non-violent rule violations.
The top rule violation leading to a stay in DSU is disobedience of an order. During
the 18-month period of the study, there were 15,433 misconduct incidents. Sixty-four percent of
these (or 9,846 incidents) resulted in a DSU sanction. Of those incidents resulting in a DSU
sanction, over half (57.5 percent) were non-violent rule violations.
ODOC’s sanctions for rule violations are governed by the Major Violation Grid and Minor
Violation Grid, which provide sanctioning options and ranges based on the severity of the
offense committed and the adult in custody’s history of misconduct. Offenses range from Level I
to Level VI, with Levels I and II encompassing the most serious and violent infractions.
Sanctions for Level I-IV violations are governed by the Major Violation Grid, and sanctions for
Level V and Level VI violations are governed by the Minor Violation Grid, which only allows loss
of privileges and/or fines to be imposed for offenses at these levels. Disobedience of an order,
the most common violation leading to a stay in DSU, is a Level III offense.

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Figure 3 below shows the top ten rule violations resulting in a DSU sanction during the 18month period. Inmate Assault I (Level I) and Inmate Assault II (Level II) are the only violent
infractions included in the top ten. Inmate Assault III, which is a Level III offense typically
applied to a less serious fight involving two adults in custody, is also in the top ten. Beyond these
three rule violations, the remaining infractions that most frequently resulted in a DSU sanction
were nonviolent.

Figure 3. Top Rule Violations Resulting in a DSU Sanction
Number of Infractions

1,600
1,200
800
400
0

Finding A4. DSU is sometimes used for Level V and Level VI violations, which is
prohibited by the Minor Violation Grid. As noted in the discussion of the previous finding,
sanctions for Level V and Level VI violations are governed by the Minor Violation Grid, which
only allows loss of privileges and/or fines to be imposed for offenses at these levels.

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As shown in Figure 4 below, 163 Level V violations and 21 Level VI violations received a DSU
sanction during the 18-month period of the study (January 2014 to July 2015). This information
is based on incident-level data, meaning that if an adult in custody was written up for multiple
rule violations at the same time, we considered the highest severity rule violation for the
information in Figure 4.

Figure 4. DSU vs. Non-DSU Sanctions Per Highest
Misconduct Severity Level

Number of Infractions

4,000

3,000

Non DSU
DSU

2,000

1,000
163

21

0
1

2

3

4

5

6

Misconduct Severity Level

Finding A5. Lengths of stay in DSU vary. 74 percent of adults in custody spent 30
days or less in DSU, but over 500 people spent 5 months or longer in DSU between
January 2014 and July 2015. From site visits and Vera’s policy review, the project team
learned that adults in custody can spend up to 30 days in DSU without a hearing. The fact that
the majority of people spend 30 days or less in DSU suggests that DSU is often used for prehearing segregation—either during investigations of potential rule violations or for
administrative hold. ODOC’s current system for entering and tracking data does not indicate
whether adults in custody are placed in DSU as the result of a sanction imposed by a hearings
officer or for temporary status or ad hold status. As a result, Vera cannot report conclusive
findings regarding how often adults in custody are sent to DSU for pre-hearing segregation.

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Figure 5 below represents the length of stay in DSU for adults in custody who entered DSU
between January 2014 and July 2015. For those who had not exited DSU by July 22, 2015, Vera
used July 22, 2015 as an estimated exit date. This affected less than one percent of the data.

Figure 5. DSU Length of Stay Distribution
Number of People

3,500
3,000
2,500
2,000
1,500
1,000
500
0

Finding A6. Adults in custody receive an average of 3-4 sanctions per disciplinary
incident.20 During the study period, 63 percent of incidents resulted in a sanction
of DSU and at least one other sanction. These additional sanctions include demotion from
contact visits to basic visits, loss of privileges (usually cell restrictions imposed following a stay
in DSU, once the person is back in general population), fines, verbal warnings, extra work,
confiscation of contraband, and good time retractions. Limitation to basic visits (non-contact
visits, which occur with a glass pane between the adult in custody and the visitor) can be
implemented for 180 days for a first major violation, one year for a first drug violation, and even
longer for additional violations—up to seven years of consecutive time. Adults in custody can get
28 days of basic visits even for minor violations.

20

An “incident” may represent one or more misconduct write-ups occurring within the same day.

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Figure 6 below shows the percentage of adults in custody who received disciplinary segregation
only, a non-segregation sanction in addition to disciplinary segregation, and a non-segregation
sanction only. This information is recorded at the incident level, meaning that adults in custody
might be written up for multiple rule violations and receive multiple sanctions for one incident.

Figure 6. Sanctions Imposed at Incident Level
DSU Only
1%

DSU +
Additional
Sanction
63%

Nonsegregation
Sanction Only
36%

Finding A7. Adults in custody experience a number of collateral consequences
from a sanction to DSU. These restrictions—all of which can be imposed for certain
violations and some of which are a consequence of DSU placement—include incentive-level
reduction, program failures and/or loss of eligibility for certain programs, loss of employment,
loss of housing, and loss of recreation yard time. The collateral consequences of a felony
conviction in the community (e.g., voter disenfranchisement, public housing restrictions,
employment restrictions) and their negative impacts on people reentering society after
imprisonment are well documented.21 The collateral consequences of a DSU sanction for adults
in custody reentering general population are similarly harmful. During a focus group with adults
in custody, Vera heard more complaints and concerns about the losses and restrictions that flow
from a sanction to DSU than we heard about DSU itself. Several men spoke of how losing their
incentive level or job filled them with despair and made them question whether they should
strive to accomplish anything in prison when their accomplishments could so easily be stripped
away.
21

See Ram Subramanian, Rebecka Moreno, and Sophia Gebreselassie, Relief in Sight? States Rethink
the Collateral Consequences of Criminal Conviction, 2009-2014 (New York: Vera Institute of Justice,
2014).

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Finding A8. Adults in custody frequently lose segregation yard privileges as a
sanction while in DSU. 1,807 “loss of segregation yard privileges” sanctions were imposed on
adults in segregation during the study period; 96 percent of those sanctions were given in DSU.
On average, those sanctions amounted to 17 days of lost recreation time. As it is, people in DSU
receive very limited access to out-of-cell exercise. According to “Oregon Administrative Rule
(OAR) 291.011-0060,” which governs services and activities in disciplinary segregation, “adults
in custody in disciplinary segregation will be provided an opportunity to exercise a minimum of
40 minutes, which includes shaving and showering, per day, five days a week.” Although “OAR
291.011-0064 Forfeiture/Deprivation of Service or Activity” allows services and activities to be
denied as a result of a disciplinary sanction, it is concerning that a large number of people
receive loss of this already minimal out-of-cell recreation time as a sanction.
Additionally, although adults in custody lose their segregation yard privileges more
frequently in DSU, they also lose yard privileges in other types of segregation. Access to out-ofcell exercise is similarly limited in these other housing units, making it equally problematic that
people in these units are losing this opportunity for out-of-cell recreation time.
Figure 7 shows the number of people and average number of days that an adult in custody was
sanctioned to loss of segregation yard privileges per misconduct severity level.

Figure 7. Loss of Segregation Yard Privileges
Misconduct Severity
Level
1
2
3
4
5
6
Total

N

Mean (Days)

687
163
598
231
112
22
1,813

25.6
16.2
13.3
9.1
6.5
5.9
17.2

Finding A9. Young adults in custody (age 25 and under) are over-represented in
DSU. Young adults comprise 11.2 percent of the total prison population but 30
percent of the DSU population.

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Figure 8 shows the breakdown of the DSU population and the total prison population by age on
the snapshot date, April 1, 2015.

Figure 8. DSU Population vs. Total Prison Population by Age
60%
Percent of Population

Total Prison Population
DSU
40%

20%

0%
18-25

26-40

Age

41-50

51+

Finding A10. ODOC’s maximum DSU sanction of 120 days with a possible upward
deviation of 60 days (for a total of 180 days) is long compared to other
jurisdictions. Over the last decade, a number of state correctional systems have taken steps to
reduce the maximum length of time an adult in custody can spend in disciplinary segregation. In
August 2016, the Delaware Department of Correction established 15 days as the maximum
segregation sanction for a single disciplinary incident or series of related incidents.22 Several
states have settled on a 30-day maximum sanction, including Washington State, Colorado, New
Mexico, and Connecticut. In Connecticut, an adult in custody can receive more than one
sanction per incident and serve disciplinary time either concurrently or consecutively, but the
total length of time cannot exceed 60 days.23
Finding A11. Reviews of adults in custody in DSU are limited and inconsistent. Both
“OAR 291-011 Segregation (Disciplinary)” and “OAR 291-105 Prohibited Inmate Conduct and
Processing Disciplinary Actions” describe avenues of review for adults in DSU. “OAR 291-011”
describes situational reviews for adults in custody to ensure they are held in DSU for the
shortest time possible to achieve the purpose for assignment to DSU. It specifies that the Special
Needs Inmate Evaluation Committee (SNIEC) will review every person in DSU at least every 30
days. “OAR 291-105” states that the functional unit manager or a designee can make an
22

Community Legal Aid Society, Inc. v. Coupe, No. 15-688 (D.D.E. Sept. 1, 2016).
See State of Connecticut Department of Correction, “Directive Number 9.5 Code of Penal Discipline”
(effective February 1, 2016), in Administrative Directive, Chapter 9: Classification,
http://www.ct.gov/doc/LIB/doc/PDF/AD/ad0905.pdf (accessed October 24, 2016).
23

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adjustment to an adult in custody’s sanction based on evidence of significant positive behavioral
change or based on a recommendation from an employee.
In practice, however, any adjustment is made only after an adult in custody has completed
an Adjustment to Final Order form. The policy reads as if staff fill out this form, but staff told
Vera that the onus is usually on the adult in custody to request and fill out the form. Once
completed, the form goes to the SNIEC, which reviews the form and makes a recommendation
on whether to reduce the person’s sanction to DSU. The possible reductions are fixed according
to the Adjustment to Final Order Grid attached to the Prohibited Inmate Conduct Rule, and are
quite short. For example, on the low end, a person who demonstrates 30 days of significant
positive behavioral change is eligible for a reduction of 8 days. At the highest end of the range,
someone who demonstrates 120 days of significant positive behavioral change is eligible for a
reduction of 17 days. The SNIEC has no discretion in deciding an appropriate reduction. Once
SNIEC has made its recommendation, the superintendent approves or denies the reduction.
Finding A12. ODOC’s conduct order system is a useful informal mechanism for
addressing lower level infractions on the unit, but it is not applied fairly or
consistently. ODOC’s conduct order system enables officers to respond immediately to lower
level infractions such as disobedience, disrespect, and horseplay by issuing a sanction via a
“conduct order.” Sanctions for lower level violations range from having the adult in custody
write an apology letter, to extra work detail, to being “celled-in” for up to 72 hours. Block
sergeants review and oversee the conduct orders for cell-in sanctions up to 24 hours; beyond 24
hours, the officer-in-charge provides review and oversight. Although the conduct order is a great
tool for swiftly imposing alternative sanctions, Vera heard during site visits and focus groups
that it is not always applied fairly and consistently. A number of the adults in custody reported
that officers tend to apply the maximum sanction—72 hours of cell-in time—rather than
imposing sanctions proportional to the conduct at issue.
Finding A13. Adults in custody in DSU spend 23 hours a day, on average, in
conditions marked by isolation, idleness, and sensory deprivation. Most DSU cells in
Oregon are small and windowless, and adults in custody are allowed very little property. With
the exception of the GED program at Two Rivers Correctional Institution (TRCI) and the limited
cognitive behavioral programming being piloted at Eastern Oregon Correctional Institution
(EOCI), adults in custody in DSU have almost no ability to engage in productive activities.
Except for people who are double-celled, which presents its own challenges, they also rarely
have meaningful contact with other people during their time in DSU.24
24
Some journalists and advocates have noted that double-celling in segregation can have dangerous
consequences. For example, see Christie Thompson and Joe Shapiro, “The Deadly Consequences of
Solitary with a Cellmate,” The Marshall Project, March 24, 2016,
https://www.themarshallproject.org/2016/03/24/the-deadly-consequences-of-solitary-with-a-cellmate
(accessed October 24, 2016).

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A number of researchers have documented the harmful effects of extremely isolating
conditions. Vera’s 2015 report Solitary Confinement: Common Misconceptions and Emerging
Safe Alternatives discusses some of the common negative impacts resulting from a stay in
segregation. These include but are not limited to hypersensitivity to stimuli, distortions and
hallucinations, increased anxiety and nervousness, diminished impulse control, severe and
chronic depression, appetite loss and weight loss, heart palpitations, talking to oneself,
problems sleeping, nightmares, and self-mutilation.25 An adult in custody may experience one or
more of these harmful impacts from a stay in DSU, which may make it difficult for him or her to
successfully transition back to general population. For instance, someone who goes back to
general population experiencing hypersensitivity to stimuli or diminished impulse control may
be easily triggered by the stimulation of a general population environment, end up committing
another rule violation, and wind up right back in DSU.
Finding A14. Conditions in DSU at minimum facilities may be experienced by
adults in custody as especially restrictive and isolating. Vera did not visit any minimum
facilities, but we heard that conditions in DSU at those facilities can be especially difficult and
stark for adults in custody placed in DSU. By policy, DSU at minimum facilities should not
extend beyond 14 days. Still, adults in custody sanctioned to DSU at a minimum facility go from
living in a fairly normalized environment, with high levels of freedom and autonomy, to
extremely isolating conditions where, by policy, they are not granted access even to outdoor
recreation.

Recommendations
Recommendation A1. Significantly reduce the number of segregation-eligible
infractions in the Major Violation Grid. Except in extremely limited circumstances (e.g.,
an escape attempt), eliminate the use of segregation for nonviolent infractions. When
segregation is used for nonviolent infractions, document the reason for imposing segregation
and institute appropriate checks and balances to ensure it is not overused or used for lengthy
periods of time.
Recommendation A2. Reduce the maximum length of stay in DSU. The cap could be
reduced to 30 days, and ODOC could assess over time whether this is effective to meet the
intended purpose of DSU or whether this time limit can be reduced further. Jurisdictions such
as those mentioned in the findings have found 30 days to be an effective maximum. However,
on the international level, the United Nations recently adopted a prohibition on prolonged
solitary confinement, which is defined as the confinement of prisoners for 22 hours or more a
25

See Alison Shames, Ram Subramanian, and Jessa Wilcox, Solitary Confinement: Common
Misconceptions and Emerging Safe Alternatives (New York: Vera Institute of Justice, 2015), p. 17.

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day without meaningful human contact for a period longer than 15 consecutive days.26 Notably,
similar rules exist in several European countries, including Germany and the Netherlands.27
Recommendation A3. Limit the use of prehearing DSU to only adults in custody
who pose a serious threat to safety or security. As described on page 13, prehearing DSU
can be used for both temporary placement, pending a disciplinary hearing, and for
administrative hold, pending a hearing to determine long-term placement in ASU or AHU. Vera
urges ODOC to follow the U.S. Department of Justice’s guiding principles, which instruct
officials to consider the seriousness of the alleged offense in determining the need for
prehearing placement in segregation, reserve prehearing placement for people who pose a
“danger” to the facility or public, require approval of such a decision by a supervisor, and call for
a review of the placement within 24 hours by a high-level authority.28
Vera recommends that ODOC:
a. Reform procedures regarding temporary placement in DSU before a
disciplinary hearing has been held.
i. Develop and require a standalone placement form (separate from the misconduct
form) for sending adults in custody to DSU for temporary placement. Require
completion of this form at the time of placement (typically by the officer-incharge). Establish procedures for a secondary review of placement by a higher
authority (e.g., a superintendent) within 24 hours.
ii. For temporary placement, ensure that the disciplinary hearing is held within 10
days or sooner, and not just scheduled or “initiated” within 10 days, as currently
required by the Prohibited Inmate Conduct Rule.
iii. To be consistent with DOJ’s guiding principles, consider removing “for the good
order” of the facility from the Prohibited Inmate Conduct Rule as a reason for
temporary placement.
b. Reform procedures regarding placement in DSU on administrative hold
status.
i. Develop and require a placement form that explains the reason for sending an
adult in custody to DSU for administrative hold. Require completion of this form
at the time of placement (typically by the officer-in-charge). Establish procedures

26

United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules),
2015, Rules 43-44.
27
In Germany, this type of confinement cannot exceed four weeks in any given year for an individual
in custody, and in the Netherlands, the limit is two weeks. See Ram Subramanian and Alison Shames,
Sentencing and Prison Practices in Germany and the Netherlands: Implications for the United States
(New York: Vera Institute of Justice, 2013), p.13.
28
See DOJ, 2016, p. 96.

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for a secondary review by a higher authority (e.g., a superintendent) within 24
hours.
ii. Lower the maximum amount of time an adult in custody can spend on
administrative hold status without a hearing from 30 days to 10 days.
c. Collect and track data on how often DSU is used for temporary
placement and administrative hold, to ensure policies are being followed.
Analyze data on a regular basis to ensure that temporary placements and ad holds
are only used when an adult in custody’s presence in general population poses a
“danger” to the facility or other incarcerated people.
Recommendation A4. Review instances where DSU has been used as a response to
minor offenses and correct issues leading to that practice. Ensure that policy is
followed and DSU is never used for Level V and VI offenses. Tracking and analyzing all
admissions to DSU and reasons for admission, as described in Recommendation A15, will assist
in monitoring compliance with this policy.
Recommendation A5. Enhance supports, structured activities, and programming
in general population to keep people from going into DSU, particularly high-risk
groups (such as young adults and those with identified mental health needs).
a. Examine correctional case management practices and ensure that adults
in custody are receiving appropriate levels of contact and supervision
from their counselors.
i. Consider expanding the therapeutic treatment planning and management level
reserved for people who have an MH3 mental health designation under “OAR
291-207-0005, Correctional Case Management” to (at least) people with an MH2
designation.29
ii. Assess whether young adults in custody typically meet the criteria for intensive
case management. If they do not, consider implementing a pilot program that
provides intensive case management to young adults and determine whether that
level of case management impacts their likelihood of going to DSU. Increased
29
In ODOC, mental health treatment providers assess adults in custody and assign them a mental
health code based on their diagnosis according to the Diagnostic and Statistical Manual of Mental
Disorders and their level of functioning. An MH1 code is assigned to adults in custody who have
diagnoses of mild acuity that do not require treatment services. The fact that individuals with a code
of MH1 or higher comprise 61 percent of the DSU population indicates that the majority of people in
DSU have some sort of mental health diagnosis ranging from mild (MH1) to severe (MH3). Beyond
these numerical codes, ODOC also uses the code MHR to classify adults in custody who meet the
diagnostic criteria for a code of MH1 and either take psychotropic medications or have moderate to
severe symptoms. It can also be used temporarily until a more comprehensive evaluation is completed.

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access to counselors during the first months of incarceration may also help
alleviate stress and reduce the potential for young adults to act out because they
fear living in general population.
iii. Consider implementing a system where a major misconduct triggers an in-person
meeting with a counselor. The agency might also consider creating a system
where repeat minor misconducts or conduct orders for the same adult in custody
trigger an in-person meeting with a counselor. During this meeting, the counselor
could review the case plan with the adult in custody and consider whether to
increase that person’s level of case management, even temporarily. More
importantly, such a meeting would provide an opportunity for the counselor to
explore with the individual the underlying causes of his or her misbehavior. This
may also help improve communication between counselors and adults in custody,
surface problems the adult in custody is experiencing that may be contributing to
minor rule violations, and help the person get back on track before he or she
commits a major rule violation and winds up in DSU.
b. Examine strategies that may help adults in custody alleviate stress and
reduce their likelihood of breaking the rules. These may include assigning
newer adults in custody to peer mentors who can help with their adjustment or
conducting orientations for new intakes about what to expect at different facilities.
Another strategy worth exploring is expanding the use of Blue Rooms or other deescalation spaces to general population housing units. (See Section B for more on
Blue Rooms.) Repurposing unused cells or other spaces in this way would give people
a place to cool off after a frustrating experience or interaction and could potentially
reduce their risk of committing an infraction in a heated moment.
c. Expand privileges and programming in general population. This could
entail any number and type of privileges or programs that give people the skills and
tools they need to be successful in general population. ODOC might choose to
develop new cognitive behavioral programs, increase access to current educational
programs, and/or expand animal programs like the Rehabilitation of Offenders and
Canines (ROC) program. Vera was extremely impressed with the ROC program and
encourages ODOC to replicate this or similar dog programs at other institutions. We
particularly recommend that ODOC find ways to introduce dogs into the DSUs and
other segregated housing units.
Giving adults on the security threat management (STM) caseload the ability to
earn privileges or access to programs may incentivize positive behavior in that
population. “OAR 291-069-0200, Security Threat Management” outlines how adults
in custody who present an elevated security threat risk are identified and managed by
trained STM managers. The policy states that adults in custody on the STM caseload
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may be subjected to intensive supervision and restriction or suspension from
departmental programs and services. In a focus group of adults in custody, several
men described how ending up on the STM caseload can mean repeated punishment
and scrutiny for minor infractions. They expressed discouragement over how difficult
it can be to succeed or move off of the STM caseload once placed on it. Giving adults
in custody the ability to earn privileges or access to programs while on the STM
caseload may encourage better behavior and lead to more successful outcomes for
those identified as high security threats.
Recommendation A6. Create intermediate housing units where adults in custody
can be placed after a DSU stay if it is determined, through a multidisciplinary
review process, that they are not yet ready for general population but do not
require the level of secure supervision provided in the intensive management unit
(IMU). If ODOC implements the types of reforms recommended in this report, DSUs across the
state will be less full, making it feasible to repurpose sections of those units for intermediate
housing units.
Both the Ohio Department of Rehabilitation and Correction and the Pennsylvania
Department of Corrections have begun piloting these types of housing units. For example, in
August 2015, Warden Michele Miller at Ohio’s Belmont Correctional Institution opened a
“limited privilege housing unit.” In Ohio, these units function as an alternative to highly
restrictive disciplinary segregation. Incarcerated people can be sanctioned to this unit for a
maximum of 90 days and are reviewed every 30 days to determine if continued placement is
necessary. On average, people spend 4-5 hours per day out of their cells engaged in
programming and other activities, including one hour for recreation, which may be spent in
general population recreation yards. Individuals who are ready for release to general population
can complete any outstanding programming in general population. Since the advent of the
limited privilege housing unit at Belmont, Warden Miller reports a drop in the number of
incarcerated people going into the facility’s more restrictive Transitional Program Unit (from an
average of 103 in 2014 to 71 in 2015).30 In Pennsylvania, the State Correctional Institution
Laurel Highlands has also begun piloting a similar limited privilege housing unit.
ODOC could choose to pilot this idea at EOCI, where security staff and a correctional
counselor have already begun to experiment with limited programming in DSU. Regardless of
how ODOC proceeds, these units should be distinct from DSU and mirror general population to
the extent possible, allowing for significantly more out-of-cell time than allowed in DSU, fewer
restraints, more congregate activity, contact visits, and increased programming. Additionally,
these units should only be used when the multidisciplinary review of an adult in custody
uncovers a significant concern about that person releasing to general population. In instances

30

Warden Michele Miller, phone call with Vera project team, May 11, 2016.

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where there are no concerns or red flags, the default placement upon release from DSU should
be general population.
Intermediate housing units could also function as an alternative to DSU altogether for
certain types of rule violations or certain types of individuals (e.g., people with MH3 or DD3
designations; see Recommendation C2). To use these units as alternatives to DSU, ODOC would
need to establish appropriate time limits for stays in these units, with weekly multidisciplinary
reviews to determine whether an adult in custody can be moved to general population. Vera
recommends considering 30 or 60 days as the maximum time limit. These units should be
established in a way that allows for continuation or completion of programming in general
population.
Recommendation A7. Discontinue the practice of imposing additional
punishments on adults in custody sanctioned to DSU. Disciplinary segregation should
be a standalone punishment and not combined with other sanctions. Imposing multiple
sanctions, including segregation, for a single incident is unduly harsh and creates a system of
discipline that is more punitive than positively incentivizing.
Recommendation A8. Revise policy regarding loss of contact visits as a sanction.
Contact visits should be restricted to basic visits only when there is a pressing
concern about safety and security. In those circumstances, implement short time limits for
restricting contact visits. Consider using 28 days as the maximum.
Restricting visits from family and other support people can be devastating for incarcerated
people and their loved ones, and counterproductive from a facility management perspective.
During a focus group with adults in custody, two men had lost contact visits for seven years and
spoke about how that, more than anything else, had made them lose their hope and motivation
to succeed while in ODOC custody. Vera’s Family Justice Program has produced several reports
that speak to the importance of maintaining family engagement for both the incarcerated person
and his or her loved ones. In these reports, Vera cites research showing how family visits can
lead to better outcomes, including a lower risk for recidivism, for the incarcerated person.31
Recommendation A9. Eliminate loss of segregation yard time as a sanction in DSU.
Adults in custody in DSU need fresh air, sensory stimulation, and exercise; they should not be
deprived of these fundamental needs for punitive reasons.

31
For example, see Margaret diZerega, Why Ask About Family? A Guide for Corrections (New York:
Vera Institute of Justice, 2011). The Mandela Rules also speak to the importance of allowing
incarcerated people to maintain family contact by stating that “[d]isciplinary sanctions or restrictive
measures shall not include the prohibition of family contact.” See United Nations Standard Minimum
Rules for the Treatment of Prisoners (the Nelson Mandela Rules), 2015, Rule 43.

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Recommendation A10. Reduce the number of collateral consequences that flow
from a sanction to DSU. In particular, eliminate the practice of imposing automatic
incentive level demotions (incentive point deductions) as a consequence of receiving a sanction
to DSU, which can lead to adults in custody losing their jobs or housing.32 If ODOC retains the
practice of imposing incentive level demotions, consider enacting reforms that would shorten
the length of time required for upward movement and allowing for shorter or more flexible
timeframes. ODOC should take steps to ensure that decisions about restoring an adult in
custody’s incentive level are made on a case-by-case basis. In cases where adults in custody have
lost their jobs as a result of a stay in segregation, ODOC should consider giving them their jobs
back, or evaluating them for the possibility of returning to their jobs.
Recommendation A11. Discontinue use of the Adjustment to Final Order form and
grid as the mechanism for initiating reviews and time reductions for adults in
custody in DSU. Implement a more meaningful automatic review process that is
triggered at regular intervals (e.g., every seven days), and establish new guidelines
on allowable time reductions. Allow for a staff-initiated review process if a staff member
thinks an adult in custody is ready to return to general population before the next scheduled
review. Track and review time reductions in DSU to determine if people actually get out of DSU
early and whether any changes need to be made to the review process.
Recommendation A12. Strengthen the procedures governing conduct orders to
improve the fairness and effectiveness of informal sanctions. Communicate to
staff and adults in custody how and when conduct orders will be used.
a. Institute a detailed response matrix to ensure that conduct orders are used
and applied fairly, consistently, and progressively.
b. Ensure that behavioral expectations and consequences for misbehavior are
understood by staff and adults in custody.
c. Institute procedures requiring staff to discuss the reason for the conduct
order with the adult in custody being sanctioned.
d. Establish meaningful oversight of the sanctions imposed to ensure that
sanctions are fairly applied and proportionate.

32

ODOC offers incentives and monetary awards to encourage and reward good institutional conduct
through its Performance Recognition and Awards System (PRAS). Through PRAS, adults in custody
earn performance points based on their behavior and completion of assigned programming. As they
accrue points, they can promote to higher incentive levels, which give them access to additional
property and the ability to apply for additional programs, activities, and incentive housing. Adults in
custody can also receive incentive level demotions as a disciplinary sanction, which means they lose
access to whatever privileges or gains they have acquired and have to earn them back.

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Since the 1970s, a well-documented body of criminal justice research has extolled the
deterrent benefits of “swift, certain, and fair” punishment over more delayed and severe
punishments.33 Most of this research has focused on community corrections (mainly probation
and parole), but its principles of behavioral modification also apply to institutional corrections.
Briefly, the idea is that behavioral expectations and sanctions for breaking the rules are
communicated to the target group, which for ODOC would be adults in custody. This
communication creates a type of social contract, which enhances the perceived fairness of any
sanctions imposed for breaking the contract. If, after learning the rules and consequences for
breaking them, an adult in custody violates a rule, proportionate sanctions are delivered
immediately (swift) and consistently (certain).34 With the conduct order system, ODOC has a
process for swift sanctioning on the unit for minor rule violations; the agency simply needs to
shore up the procedures for applying those sanctions to ensure fairness and certainty.
Recommendation A13. Improve conditions of confinement in DSU. In addressing
conditions of confinement, DOJ’s guiding principles on the use of restrictive housing call on
correctional systems to seek ways to increase the minimum amount of time that adults in
custody in restrictive housing can spend outside their cells and to offer enhanced in-cell
opportunities. DOJ also recommends out-of-cell, confidential psychological assessments and
visits for adults in custody.35 Notably, the Colorado Department of Corrections reached a
settlement agreement in July 2016 regarding a class action lawsuit brought on behalf of inmates
in administrative segregation who had been denied access to outdoor exercise and fresh air. The
attorneys argued that denial of fresh air violated the 8th Amendment’s prohibition on cruel and
unusual punishment.36 Vera recommends that ODOC:
a. Allow more opportunities for out-of-cell time and congregate activity.
Increase the amount of out-of-cell recreation time afforded to adults in custody. Provide
daily outdoor recreation time for all adults in custody in DSU, including those housed in
minimum-security facilities. Consider assessing adults in custody in DSU and matching
some people for compatibility to have congregate yard time.

33

For example, see Valerie Wright, Deterrence in Criminal Justice: Evaluating Certainty vs. Severity of
Punishment (Washington, DC: The Sentencing Project, November 2010); Mark A.R. Kleiman and
Angela Hawken, “Fixing the Parole System,” Issues in Science and Technology Volume XXIV, Issue 4
(Summer 2008), http://issues.org/24-4/kleiman/ (accessed October 24, 2016); and Swift Certain &
Fair, http://www.swiftcertainfair.com/ (accessed July 6, 2016).
34
Swift Certain & Fair, “Why Swift Certain & Fair,” http://www.swiftcertainfair.com/why-swift-certainand-fair/ (accessed July 6, 2016).
35
See DOJ, 2016, p. 99.
36
See Susan Greene, “Legal settlement ends Colorado’s practice of denying inmates fresh air,” The
Colorado Independent, July 5, 2016, http://www.coloradoindependent.com/160085/coloradosettlement-inmates-fresh-air (accessed October 24, 2016).

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b. Create more opportunities for productive activities in-cell. Consider installing
televisions or handing out MP3 players or tablets that could deliver programming or
entertainment to adults in custody.37
c. Create Blue Rooms or de-escalation rooms in DSU units, perhaps by converting
a DSU cell not in use. See Recommendation B4 for more detail on Blue Rooms and deescalation rooms. Establish a system that allows all or most adults in custody to access
these spaces for meaningful periods of time.38
d. Examine the physical space of DSU cells and recreation spaces and identify
changes that can be made to increase size and natural light. For example,
replace the frosted windows in the DSU cells at EOCI and OSP with clear windows.
Based on a suggestion by Vera staff during the tour of the Oregon State Penitentiary,
OSP staff decided to remove the louvers from the BHU’s outdoor recreation yard, which
has increased the openness and amount of light and air in the space. Vera recommends
removing any louvers used in DSU recreation yards and expanding the size of yards. At
some facilities like CCCF, outdoor segregation recreation spaces are so small that adults
in custody barely have space to walk.
e. Explore the impact of double-celling on the safety and well-being of adults in
custody housed in double-celled DSUs. If the assessment reveals negative impacts
(e.g., more assaults or trips to the infirmary), develop a plan to reform or end doublecelling practices. In all cases, when double-celling is used, ensure that adults in custody
are carefully matched to minimize the risk for dangerous situations occurring. Note,
however, that if conditions of confinement in DSU change to allow significantly more
out-of-cell time, the potential negative impacts of double-celling in DSU may be
decreased.
f. Ensure that qualified mental health professionals (QMHPs) or health
services practitioners are doing in-person mental health assessments (and
not just chart reviews) within 24 hours of a person’s placement in DSU.
g. Allow adults in DSU telephone privileges to speak with family and other
outside support people. At EOCI, adults in custody in DSU who engage in positive

37
In 2008, the Hampden County Sheriff’s Department in Massachusetts began distributing preprogrammed MP3 players to inmates in segregation as a reward for demonstrating positive behavior
and following the rules. The material programmed into the MP3 players includes self-help audio
programs, treatment programs, contemporary and classical music, nature sounds, and audio books.
The Sheriff’s Department has found MP3 players to be a cost-effective way to keep inmates engaged
in productive activities and to reinforce positive behavior. For more on the Hampden County Sheriff’s
Department’s use of MP3 players, see Francis Olive and John Evon, “The Utilization of MP3 Players in
Correctional Segregation Units,” Corrections Today 74, no. 6 (December 2012-January 2013): 53.
38
Colorado has introduced de-escalation rooms in its segregation units, where inmates can go when
they need a “timeout” to cool down. These rooms often have soothing wall colors, dim lights, and a
comfortable chair. Individuals can listen to calming music, use exercise balls, read, and participate in
art therapy. See Rick Raemisch and Kellie Wasko, Open the Door: Segregation Reforms in Colorado
(Colorado Springs, CO: Colorado Department of Corrections, 2015).

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behavior (e.g., making their beds and keeping their cells clean) and receive no
misconduct reports for 30 days can earn one free 15-20 minute phone call. Staff at EOCI
discussed how impactful and calming these calls are on the adults in custody and noted
that loved ones often reinforce ODOC’s message that the incarcerated person needs to
follow the rules. Consider expanding this privilege across institutions and reducing or
eliminating the conditions attached to using the phone.
h. Increase the number and length of basic visits afforded to adults in custody
in DSU who have demonstrated positive behavior. By policy, adults in custody
are afforded one basic visit per week for one hour while in DSU, but some facilities have
increased the number and duration of basic visits as a reward for positive behavior. For
example, at EOCI, if individuals have been involved in programming and maintained
clear conduct for 30 days, they can request a two-hour visit, which serves as a
reinforcement for positive behavior.
Recommendation A14. Reform the use of DSU at minimum-security facilities. Vera
encourages ODOC to examine how DSU is currently used at minimum-security facilities to see if
there are ways to reduce the use of DSU that are unique to those facilities. ODOC should take
steps to ensure that the reforms implemented at the medium-security facilities and OSP are also
applied to the minimums.
Recommendation A15. Collect and track data on ODOC’s use of disciplinary
segregation. This would ensure an ability to assess whether there is consistent application of
policies. It will also allow ODOC to assess whether policies are achieving a reduction in the use
of disciplinary segregation and to continue to examine ways to reduce the use of disciplinary
segregation.

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B. Administrative Segregation
The findings and recommendations below address ODOC’s Intensive Management Unit (IMU),
Administrative Segregation Unit (ASU), and Administrative Housing Unit (AHU).39

Findings
Finding B1. 549 adults in custody moved from DSU to IMU during the 18-month
study period (January 1, 2014 to July 22, 2015). Of those, nearly half (48 percent)
spent 4 or more months in DSU before entering IMU. In practice, this means that
people whom ODOC has identified as needing programming to correct negative thinking or
behavioral patterns spend months in DSU without access to such programming before they are
moved to IMU.
Figure 9 below shows the amount of time adults in custody spent in DSU before ultimately being
transferred to IMU.

Figure 9. Length of Time in DSU before Entering IMU

Number of People

160
120
80
40
0

Length of Stay in DSU

39

Note that Findings B3 and B8 below include reference to the Behavioral Health Unit (BHU), and
Recommendation B5 encompasses the BHU. Otherwise, findings and recommendations pertaining to
the BHU and other mental health issues appear in Section C. Mental Health.

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Finding B2. Lengths of stay in IMU vary. A majority (55 percent) of people spent 6
months or less in IMU, but 45 percent stayed in IMU for over 6 months. And over
12 percent spent more than 1 year in IMU.
Figure 10 below shows the amount of time adults in custody stayed in IMU.

Figure 10. IMU Length of Stay

Number of People

80
60
40
20
0

Length of Stay

Finding B3. Adults in custody who had contact with IMU typically spent over a year
total in some form of segregated housing. This includes ASU, DSU, IMU, BHU,
MHI, and segregation at intake.
Figure 11 below shows the total length of stay in all types of segregated housing for adults in
custody who had contact with IMU at some point during their segregation stay. Fifty-nine
percent of people who had contact with IMU were in segregation for over one year. Three people
remained in segregated housing for five years.

Number of People

Figure 11. Total Stay in Segregated Housing that Includes
Contact with IMU
160
120
80
40
0

Length of Stay

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Finding B4. Adults in custody usually spent 150 days (about 5 months) in IMU
before receiving their first review. In 2014, ODOC implemented a first review of adults in
custody’s IMU status at 150 days and subsequent reviews at 90-day intervals. The goal was to
provide a more meaningful review of their IMU status. Staff told the Vera team that this new
review process contributed to a decrease in the IMU population at Snake River Correctional
Institution (SCRI). From January 2014 to October 2015, the IMU population decreased from
about 280 people to around 150. Despite this improvement in reviews of IMU status, 150 days is
still a lengthy period of time for adults in custody to spend in IMU with no review.
Finding B5. Programming in IMU was limited to packets that adults in custody
were expected to complete alone in their cells. Packet-based programming is not optimal
for helping adults in custody correct negative behavioral patterns or thought processes, since it
entails little-to-no interaction with teachers, counselors, or others who can work with them to
explain concepts and practice skills. Packet-based programs can also be difficult for people who
are limited English proficient or who have low IQs or low reading ability. Both SRCI and Coffee
Creek Correctional Facility (CCCF) have begun implementing instructor-led cognitive behavioral
treatment programs in classrooms outfitted with secure program chairs.40
Finding B6. The Blue Room in IMU Housing Unit E at SRCI is a notable example of
staff-driven innovation, but it is only available to a small segment of the IMU
population. It helps calm adults in custody who have access to it and has improved
the working environment for staff on that unit. The idea for the Blue Room—a converted
indoor recreation space in IMU Housing Unit E where nature videos and sounds are projected
on the wall to have a soothing effect on adults in custody—came from a corrections officer. Since
creating the Blue Room in 2014, SRCI has seen a decline in violent episodes and cell extractions
for adults in custody who have access to the room. It costs about $1,500 a year to maintain, and
security and behavioral health staff report that the Blue Room has led to a calmer, less chaotic
environment in the IMU. During Vera’s focus group with adults in custody, those who had spent
time in the Blue Room noted that it was helpful. Additionally, Time magazine named the Blue
Room one of its top 25 inventions of 2014, and the concept is so popular among ODOC staff that
Vera heard suggestions of creating a similar space for staff at SRCI and creating these spaces in
general population units at EOCI.
Finding B7. Placing adults in custody safely in general population units after a stay
in IMU is a challenge for staff, potentially extending their stay in IMU. During site
visits, staff and administrators talked about the difficulty of finding safe housing options for
40

Secure program chairs are desks with chairs that have been specifically designed to enable people
to be cuffed and shackled into the seat. Most swivel to allow people to turn and face different
directions in the room.

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adults in custody who have completed their time in IMU. Finding safe housing can be
challenging for a number of reasons. In the men’s prisons, it may be hard to find a safe place for
someone who has had conflicts with other security threat groups or who has denounced his own
security threat group. In the women’s prison, staff have very few housing options, since a
woman coming out of IMU has to remain at CCCF. If a woman in IMU has had a history of
conflict or violence with other women, she may remain in IMU for a longer period of time while
staff try to figure out where to house her in general population.
Finding B8. ODOC does not have a structured reentry process or step-down
program for adults in custody leaving IMU, ASU, or BHU and reentering the
general population or the community. During the 18-month period Vera studied,
348 people were released directly to the community from segregated housing. Their
average length of stay in segregated housing directly preceding release to the community was
147 days (almost 5 months), and 27 percent of these adults in custody were in segregated
housing for more than 6 months before their release.
Figure 12 below shows the number of adults in custody entering the community directly from
segregation, within one week of their segregation stay, and between one and two weeks of their
segregation stay, during the 18-month study period. In addition to the 348 people released
directly to the community from segregation, another 53 were released to the community after
spending 1-7 days out of segregation, and 48 were released after spending 7-14 days out of
segregation.

Figure 12. Frequency of Releases from Segregation
to Community

Number of People

400

348

300

200

100

53

48

Released to community
within 1 week of seg

Released to community
within 2 weeks of seg

0
Released to community
from seg

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As shown in Figure 13, during the 18-month study period, 449 adults in custody were released to
the community from segregation or within two weeks of a segregation stay. The graph below
shows the amount of time these individuals spent in segregation before their release.

Figure 13. Time Spent in Segregation before Release to
Community
Number of People

50

25

0

Finding B9. Adults in custody serving time in IMU and ASU spend 23 hours a day,
on average, in conditions marked by isolation, idleness, and sensory deprivation.
Although individuals in IMU are given worksheets to complete and have cognitive behavioral
treatment meetings with a counselor once a week, for an hour, they spend most of their time
alone in their cell.41 Additionally, the Blue Room is a helpful resource, but only adults in custody
in Unit E have access to it, and currently it is used mainly for those with mental health needs. In
ASU, adults in custody have property in their cells similar to those in general population, but
they are only out of their cells one hour a day for recreation and 20 minutes a day for showers.
See the discussion under Finding A13 for more on how these conditions can negatively impact a
person’s well-being and successful transition to general population or the community.
Finding B10. ODOC’s AHU for adults requiring protective custody resembles a
general population unit. TRCI houses the AHU, which is ODOC’s main designated
protective custody unit. TRCI leaders and staff have worked hard to structure AHU so it
resembles a general population housing unit as closely as possible. Adults in custody assigned to
AHU are on the unit most of the day, but not restricted to their cells. The unit has programming
space and an outdoor yard. Some people work in the kitchen at night, and they get to have a
family picnic each year. Although they have been restricted to basic visits in the past, ODOC
reports that they will be able to have contact visits soon.
41

Adults in custody in IMU are sometimes double-celled.

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Finding B11. ODOC’s administrative rules, policies, practices, and data tracking
regarding segregation are not always consistent. For example, the ASU policy has no
minimum recreation time, but others do.

Recommendations
Recommendation B1. For adults in custody in DSU who have been flagged for
possible IMU placement, conduct evaluations for placement in IMU sooner, so
those individuals do not spend months in DSU before gaining access to IMU
programming. Note that if ODOC reduces the maximum length of time an adult in custody
can spend in DSU to 30 days, this will no longer be as great of an issue. However, regardless of
the maximum length of stay in DSU, transfers to IMU should occur as soon as possible after
IMU placement decisions have been approved.
Recommendation B2. Review adults in custody placed in IMU at shorter intervals.
Start with 30 days and assess over time whether this is an effective timeframe for tracking
progress and reviewing suitability for release back into general population. Allow adults in
custody who are ready to release from IMU to complete any remaining programming once back
in general population.
Recommendation B3. Implement instructor-led programming in a classroom
setting in IMU. In-cell worksheets or packets should not function as the sole component of
IMU programming. As noted in the findings, both SRCI and CCCF have been taking steps to
transition their programming from worksheets to instructor-led CBT programs in classrooms
outfitted with secure program chairs. Vera encourages ODOC to continue implementing this
programming and recommends learning from the work done in other states to create
opportunities for classroom programming in administrative segregation settings. For more
information on other state efforts, see the discussion of step-down units and transitional
programs under Recommendation B5 below.
Recommendation B4. Create more Blue Rooms or other types of de-escalation
spaces where adults in custody living in segregated units can spend time. Currently,
in Oregon and Colorado, spaces like these are reserved for people with mental illness.
Washington State also has nature imagery spaces at the prison where staff operate a skillbuilding unit for people with intellectual disabilities. Except in extremely limited circumstances
where there is pressing concern about safety or security, Vera encourages ODOC to allow all
adults in custody access to these spaces. Additionally, ODOC may find it helpful to review

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Colorado’s policy on de-escalation rooms.42 Though similar to ODOC’s Blue Room in that deescalation rooms are designated spaces where adults in custody can take a “timeout” from the
noise and stress of the segregation environment, incarcerated people in Colorado can request to
go into the de-escalation rooms, stay as long as they feel they need, and then request to leave.
This gives them more autonomy and allows them to practice self-regulation.
Consider creating similar spaces for staff who work on these units, to help with their stress
management. Finally, consider adding these types of spaces in general population. See
Recommendation A5 in the preceding section for more on the idea of creating Blue Rooms or
de-escalation spaces in general population.
Recommendation B5. Create a structured reentry process and/or step-down units
for adults in custody transitioning out of long-term segregation. Ensure that adults
in custody are never released directly to the community from segregation. In
practice, release to the general population means that people in segregated housing go from
living in very restrictive, isolated environments to living in double cells or dorms where they are
surrounded by people. The contrast is even starker for people who release directly from
segregation to the community. As discussed in the previous section, people experience a number
of potentially devastating effects while in segregation, which may make it difficult for them to
successfully transition back to general population or to the community. These include but are
not limited to hypersensitivity to stimuli, distortions and hallucinations, increased anxiety and
nervousness, diminished impulse control, severe and chronic depression, appetite loss and
weight loss, heart palpitations, talking to oneself, problems sleeping, nightmares, and selfmutilation.43
To prevent this, Vera recommends that ODOC create an assessment process to determine
which adults in custody may require reentry support (either for returning to the community or
to general population) and which ones would benefit from a step-down unit. Generally, the goal
of all step-down units and transitional programs is to help people successfully re-enter general
population housing or the community after a stay in segregation. These units and programs can
be structured in different ways, but most include graduated levels of structured out-of-cell time
and congregate activity. One approach that has been implemented in a number of jurisdictions
is creating a phase or level system where incarcerated people can work their way out of
segregation and gradually earn privileges and services as they move through the program. For
this approach to be successful, individuals need to understand exactly what is required of them
to move through the levels, and staff need to consistently adhere to the established framework.
If implemented and communicated in this way, this type of step-down unit or program gives
42
See Colorado Department of Corrections, Administrative Regulation 650-04, Chapter: Offender
Group Living, “Residential Treatment Programs for Offenders with Mental Illness and Intellectual and
Developmental Disabilities” (effective June 15, 2016), p. 5,
https://drive.google.com/file/d/0B4vYiI52TzO6Z2hCU2xmall6VXc/view (accessed October 24, 2016).
43
Shames, Wilcox, and Subramanian, 2015, p. 17.

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adults in custody a clear roadmap for working their way out of segregation and incentivizes
them to follow the rules and participate in structured activities and programs.
Importantly, if step-down or transitional programs are not implemented and monitored
carefully, they can actually extend an individual’s time in segregation. For example, if policy
states that that when an incarcerated person violates a rule, the automatic response is to demote
the person back to the first level, no matter what level he or she is on at the time of the violation,
this can create a cycle where people consistently work their way up the level system, just to find
themselves back at the beginning after one incident. This effectively creates a system and
perception that it is impossible to get out of segregation.44 Systems can avoid this cycle if they
craft policy and procedures that enable staff to respond to violations on an individualized basis
with more graduated sanctions, rather than requiring staff to impose automatic level demotions,
recognizing that making mistakes and learning from them may be part of the behavior change
process.
Another way to effectively move people out of segregation into general population or the
community is to institute a transitional unit, where incarcerated people spend a period of time
in a less restrictive unit before going back to general population or the community. Colorado has
created two different types of these units, Close Custody Management Control Units and the
Close Custody Transition Unit. Close Custody Management Control Units are used to manage
people who have been deemed ready to progress out of segregation. In these units, incarcerated
people are allowed out of their cells 4 hours per day, 7 days a week, and with up to 7 other
incarcerated people. They also get a minimum of 3 hours of recreation and participate in prosocial group and programming activities. Individuals may progress from these units to the Close
Custody Transition Unit where they have greater out-of-cell time in larger groups.45
ODOC may find it helpful to review how these other states have created structured reentry
processes when creating processes tailored to ODOC’s needs and population.

44

Rick Raemisch and Kellie Wasko discuss this type of “revolving door” phenomenon, which existed in
Colorado’s administrative segregation units prior to instituting reforms beginning in 2013. See
Raemisch and Wasko, 2015, p. 2.
45
Ibid., p. 4.

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Transitional Programs and Step-Down Units in Other States
The Washington State Department of Corrections has implemented several transitional
programs and step-down units to move incarcerated people from intensive management units
(IMUs) back to general population or the community. The Intensive Transition Program (ITP)
at Clallam Bay Corrections Center is one notable example. ITP is a voluntary, nine-month
program in a self-contained housing unit that is designed to help individuals move out of IMU
and break the cycle of personal dysfunction through targeted programming and the progressive
development of self-control. As individuals progress through the phases, they earn more
freedoms and privileges, and classroom settings become more normalized—they eventually sit
unrestrained in groups at tables. Upon graduation, incarcerated people move to one of two
lower custody institutions that have been deemed “safe harbors.”46
Beginning in 2011, the Virginia Department of Corrections began implementing reforms at
the state’s supermax facility, Red Onion State Prison. Among the reforms was establishing a
Segregation Step-Down Program that includes cognitive behavioral journaling, the use of
program chairs for therapeutic programming, and increasing privileges as incarcerated people
progress through the levels.
The New Mexico Department of Corrections has a similar program called the Predatory
Behavior Management Program and a specific step-down program for members of security
threat groups called the Restoration to Population Program.47

Recommendation B6. Conduct a comprehensive examination of safe housing
options across ODOC for adults in custody releasing from long-term
administrative segregation. States like Washington, Pennsylvania, and New Mexico have all
explored ways to safely house compatible, at-risk groups with similar needs. These approaches
can help transition people safely out of segregation and may also reduce the number of people
going into segregation due to fears for their safety in the general population. For example,
Washington uses a “safe harbor” approach through which incarcerated people who have
completed transitional programming can step down from IMU and safely live in general
population at two designated institutions. These prisons house individuals who are less likely to
be violent, including sex offenders and adults in custody who were formerly affiliated with
gangs.48 Over the last several years, the Pennsylvania Department of Corrections has also
established various types of missioned housing for incarcerated people who might have trouble
46

This description of the ITP is based on site visits Vera staff conducted to Clallam Bay Corrections
Center in May and December of 2015, unpublished materials provided by the Washington State
Department of Corrections, and a phone call with the director of the ITP, Steve Blakeman, on
November 12, 2015. For more on “safe harbors,” see Dan Pacholke and Sandy Felkey Mullins, More
than Emptying Beds: A Systems Approach to Segregation Reform (Washington DC: Bureau of Justice
Assistance, 2016).
47
See DOJ, 2016, pp. 76-77.
48
See Pacholke and Mullins, 2016, p. 8.

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living in general population but who do not pose a significant security threat. These units
include Special Needs Units, which mix incarcerated people who are not seriously mentally ill
but who have other potential vulnerabilities in residential settings. Similarly, the New Mexico
Corrections Department has implemented missioned housing for different groups, including sex
offenders and incarcerated people with a history of drug abuse.49
Recommendation B7. Consider redesigning ASU to more closely resemble AHU. As
noted in the findings, AHU closely resembles a general population unit but is self-contained at
TRCI. Vera recommends that ODOC restructure or relocate ASU to be more like general
population, so that people assigned there have more out-of-cell time and access to productive
activities.
Recommendation B8. Improve conditions of confinement in IMU and ASU. For
reasons similar to those laid out in Recommendation A18, Vera recommends that ODOC:
a. Allow more opportunities for out-of-cell time and congregate activity.
Increase the amount of out-of-cell recreation time afforded to adults in custody. Provide
daily outdoor recreation time for all adults in custody in IMU and ASU. Consider
assessing adults in custody in these units and matching some people for compatibility to
have congregate yard time.
b. Create more opportunities for productive activities in-cell. Consider installing
televisions or handing out MP3 players or tablets that could deliver programming or
entertainment to adults in custody.50
c. Expand use of Blue Rooms or de-escalation rooms (See Recommendation
B4). This could be accomplished by converting cells not in use. Establish a system that
allows all or most adults in custody to access these spaces for meaningful periods of time.
d. Examine the physical space of IMU and ASU cells and recreation spaces and
identify changes that can be made to increase size and natural light. As
mentioned earlier, staff at OSP removed the louvers from the BHU’s outdoor recreation
yard, which has increased the openness and amount of light and air in the space. Vera
recommends removing any louvers used in recreation yards in IMU or ASU and
expanding the size of those yards where possible.
e. Explore the impact of double-celling on the safety and well-being of adults in
custody housed in double-celled IMUs. If the assessment reveals negative impacts

49

See DOJ, 2016, p. 76.
As noted in 37 above, the Hampden County Sheriff’s Department in Massachusetts began
distributing pre-programmed MP3 players to inmates in segregation as a reward for demonstrating
positive behavior and following the rules. The material programmed into the MP3 players includes selfhelp audio programs, treatment programs, music, nature sounds, and audio books. The Sheriff’s
Department has found MP3 players to be a cost-effective way to keep inmates engaged in productive
activities and to reinforce positive behavior.
50

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(e.g., more assaults or trips to the infirmary for adults in custody who are double-celled),
develop a plan to reform or end double-celling practices. In all cases, when doublecelling is used, ensure that adults in custody are carefully matched to minimize the risk
for dangerous situations occurring. Note, however, that if conditions of confinement in
IMU change to allow significantly more out-of-cell time, the potential negative impacts
of double-celling in IMU may be decreased.
f. Increase access to qualified mental health professionals (QMHPs).
Importantly, communication between QMHPs and adults in custody should not take
place at the cell door.
g. Increase access to telephone privileges to speak with family and other
outside support people. Seek ways to expand and incentivize telephone privileges.
h. Seek ways to expand and incentivize visiting privileges for adults in custody
in IMU and ASU. Consider expanding the number of visits afforded to adults in
custody in IMU.
Recommendation B9. Resolve inconsistencies across the Oregon Administrative
Rules and departmental policies governing types of segregated housing. For example,
the administrative segregation policy has no minimum required recreation time, but other
policies on segregation do. The timeframes and requirements do not need to be uniform, but the
categories of privileges and restrictions should be consistent. For example, recreation time does
not have to be the same across housing types, but all policies should address recreation time and
allow for daily outdoor exercise. Additionally, make sure policies clearly state the role and
function of mental health providers in completing assessments and participating in reviews.
Create an implementation plan and performance measures that are consistent across facilities.

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C. Mental Health
Findings
Finding C1. Adults in custody with mental health codes of MH1 or higher are
overrepresented in DSU.51 Vera found that adults in custody with mental health codes
comprised about 51 percent of the total population, but 61 percent of the DSU population on the
snapshot date.
Figure 14 below shows the breakdown of the total population compared to the DSU population
by mental health designation on the snapshot date, April 1, 2015.

Figure 14. DSU Population vs. Total Population
by Mental Health Need

Percent of Population

30%
Total Pop
DSU
20%

10%

0%
None
recorded

51

MH0

MH1

MHR

MH2

Mental Health Code

See footnote 29 above for an explanation of ODOC’s mental health codes.

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MH3

Figure 15 below shows the frequency of a sanction to DSU by mental health need, at the incident
level. Adults in custody with mental health needs made up 67 percent of incidents resulting in a
DSU sanction. Those with MH2 and MH3 codes accounted for over 33 percent of incidents
resulting in a DSU sanction.

Figure 15. DSU Sanctions by Mental Health Need
30%

20%

24.6%

24.5%

25%

17.2%

15.6%

15%

9.3%

10%

8.7%

5%
0%
None
recorded

MH0

MH1

MHR

MH2

MH3

Finding C2. Women with significant mental health needs are overrepresented in
all types of segregated housing. Fifty-three percent of the total female population on the
snapshot date had a mental health code of MH2 or MH3, while 84 percent of women in
segregated housing had a mental health code of MH2 or MH3.

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Figure 16 below shows the female population in segregation, broken down by mental health
need, on the snapshot date, April 1, 2015.

Figure 16. Female Segregated Population vs. Total
Female Population by Mental Health Need
57%

60%

Segregated
Population
42%

Total Female
Population

40%
27%
20%

16%

5%

11%

8%
2%

12%

11%

7%
2%

0%
None
recorded

MH0

MH1

MHR

MH2

MH3

Finding C3. Over two-thirds of women in DSU had a more severe mental health
diagnosis. On the snapshot date, 79 percent of women housed in DSU had a mental health
code of MH2 or MH3.
Figure 17 below shows where females were housed on April 1, 2015 and the percentage of that
population with a mental health code of MH2 or MH3.
Figure 17. Female Population with Mental Health Needs by Housing Unit

50

Unit Location

N

Percent of female
population

GP
DSU

1,256
19

96.6%
1.5%

Percent of Unit with
MH2 or MH3
52%
79%

MHI
SHU

8
17

0.6%
1.3%

88%
88%

Total

1,300

100%

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Finding C4. Adults in custody with mental health needs are more likely to have
repeat rule violations. Vera analyzed the number of individuals who had been written up on
more than five different occasions within the 18-month period of the study. Vera found that 448
adults in custody—or only 3 percent of the total ODOC population—accounted for 25.7 percent
of the 15,433 misconduct incidents. Of those 448 high utilizers, 82.6 percent had a mental
health designation, and 47.1 percent had a mental health code of MH2 or MH3.
Figure 18 below shows the number of high utilizers by mental health need. High utilizers are
individuals who were written up for more than five incidents in the 18-month study period.
Figure 18. High Utilizers of Segregation by Mental Health Need

Mental Health
Needs

Number of People Written
up More than 5 Times

Percent of High Utilizers
per Mental Health Code

None recorded

31

6.9%

MH0

47

10.5%

MH1

98

21.9%

MHR

61

13.6%

MH2

157

35%

MH3

54

2.1%

Total

448

100%

Finding C5. Adults in custody with serious mental illness (MH3 and DD3) can
remain in DSU for lengthy periods of time (up to 30 days) before being diverted to
another environment.52 After completing their DSU sanction, they may go back to general
population or be referred to the various levels of care and mental health housing within the
ODOC system. The possible placements may include mental health units, day treatment units,
the Intermediate Care Housing (ICH) unit, or the BHU (if the behavior that resulted in a DSU
sanction rose to the level that would merit an IMU placement). ODOC reports that any
individual, including those with SMI, experiencing a mental health crisis while serving a DSU
sanction can be referred to the Mental Health Infirmary.

52
In ODOC, mental health treatment providers assess adults in custody and assign them a
developmental disability code based on their diagnosis according to the Diagnostic and Statistical
Manual of Mental Disorders and their level of functioning. A DD1 code is assigned to adults in custody
who have mildly impaired functioning (IQ 80-84) and only minimal needs, while a DD3 code is
assigned to people who have severely impaired functioning (IQ below 70) and the most severe needs.

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Finding C6. ODOC’s plans for building treatment space for adults in custody in
BHU, which will ultimately enable 20 hours of out-of-cell time per week, should
vastly improve conditions of confinement and outcomes for adults in custody
placed there. When Vera’s assessment began in May 2015, Disability Rights Oregon (DRO)
had just published an investigative report detailing findings and recommendations regarding
conditions in the BHU.53 Among DRO’s concerns were that adults in custody assigned to the
BHU lacked adequate out-of-cell time (one hour or less per day) and adequate access to mental
health treatment and services. At that time, individuals were being offered one to two hours of
recreation five days a week, but were using little to none of it because of the time of day it was
offered and the lack of activities in recreation areas. ODOC was also struggling with physical
plant challenges in the Special Management Building—originally designed to be ODOC’s
“supermax” building in the 1990s—that severely limited treatment and programming space for
people housed in that building.
Since DRO’s report and the subsequent memorandum of understanding (MOU) that ODOC
entered into with DRO in 2016, ODOC has moved the ICH out of the Special Management
Building and into another area at OSP, which has freed up more indoor recreation space for
people assigned to BHU. ODOC has also increased and improved leisure activities available in
those indoor recreation areas (e.g., a wall painted with chalkboard paint and musical
instruments), and the schedule has been adjusted, so that recreation time is more frequently
used. Additionally, ODOC has repurposed some existing space in a building adjacent to the BHU
to create two programming rooms that can each hold six adults in custody. Based on safety and
willingness, rather than program level, people in BHU can now participate in a variety of
cognitive behavioral treatment programs and other therapeutic programs. Programming is
offered in 60-90 minute segments, five days a week from noon to 7:30pm. Adults in custody can
be in as many as five or six groups per week. Depending on their program level, they can also
participate in dayroom activities two times per week.
In the future, ODOC plans to increase BHS staffing resources, so that BHU residents can have
increased access to dayroom activities. Over the next few years, ODOC plans to build a new
mental health center, which will provide both the BHU and the MHI with additional treatment
space. This new mental health center will include several individual therapy rooms, as well as
two additional six-person group rooms. ODOC strongly believes that the addition of the mental
health building, and the staffing resources that will come along with it, will allow Oregon to
meet the goal of providing 10 hours of structured out-of-cell treatment and 10 hours of out-ofcell unstructured activity per week to people assigned to the BHU.

53

Joel Greenberg and Sarah Radcliffe, Behind the Eleventh Door: Solitary Confinement of Individuals
with Mental Illness in Oregon’s State Penitentiary Behavioral Health Unit (Portland: Disability Rights
Oregon, 2015).

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Recommendations
Recommendation C1. Enact policies that prohibit placing people with serious
mental illness (including those with the developmental disability code of DD3) and
neurodegenerative diseases in any form of segregated housing that limits
meaningful access to social interaction, environmental stimulation, and
therapeutic programming.54 It has been well documented in federal court cases, legal
settlements, and medical and mental health research that people with serious mental illness are
especially vulnerable to the harms of isolating conditions.55 In April 2016, the National
Commission on Correctional Health Care issued a position statement stating strongly that
people with mental illness should be excluded from solitary confinement for any duration.56
Additionally, DOJ’s guiding principle on adults in custody with serious mental illness states that
“generally, adults in custody with serious mental illness (SMI) should not be placed in restrictive
housing.”57
As previously described, ODOC already has a system of mental health housing units that
operate with different levels of care and security and has been taking steps to improve
conditions and services in the BHU. By moving the ICH out of the Special Management Building
at OSP, ODOC staff report that they have been able to provide more appropriate treatment and
programming to ICH residents as well. As ODOC moves forward with its plans to increase
mental health staffing and programming for the BHU population, Vera recommends taking a
wider approach to ensure that people with serious mental illness or developmental disabilities
are always placed in supportive environments with meaningful access to congregate activity and
programming, rather than in segregation.
Recommendation C2. Enact restrictions on placing adults in custody with MH3
and DD3 codes in DSU, and designate a small number of beds in newly established
intermediate housing units for adults in custody with MH3 or DD3 codes who
commit violent infractions. Adults in custody with serious mental illness should only be
placed in DSU in extremely rare circumstances, such as when a violent incident has occurred
and there is a pressing but time-limited need to ensure safety and security. Restricting
54

In the Behavioral Health Services Division Policy and Procedure #MH-G-01, the term Organic Brain
Syndrome is used to describe medical diseases that result in decreased mental function.
55
See Frost and Monteiro, 2016, pp. 9-12 for a synopsis of federal court cases and consent decrees.
For settlements involving the New York Department of Corrections and Community Supervision and
the California Department of Corrections and Rehabilitation, see Peoples v. Annucci, 2016 U.S. Dist.
LEXIS 43556 (S.D.N.Y., Mar. 31, 2016); and Ashker v. Governor of California, Settlement Agreement
C 09-05796 CW (N.D. California, 2015). For an overview of medical and mental health research, see
Shames, Subramanian, and Wilcox, 2015, pp. 17-18; and David H. Cloud, Ernest Drucker, Angela
Browne, and Jim Parsons, “Public Health and Solitary Confinement in the United States,” American
Journal of Public Health 105, no. 1 (January 2015): 18-26.
56
National Commission on Correctional Health Care, 2016.
57
DOJ, 2016, p. 99.

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segregation in this way is consistent with DOJ’s guiding principles regarding adults in custody
with serious mental illness. DOJ states that incarcerated people with serious mental illness
should be diverted to a clinically appropriate form of housing; and in cases where they end up in
segregation, DOJ provides clear guidelines for conditions and treatment, including providing
incarcerated people with intensive, clinically appropriate mental health treatment during their
stay in segregation.58
If ODOC decides to create intermediate housing units and designate several beds in each
unit for adults in custody with serious mental illness (SMI), it will need to ensure that those
units have appropriate levels of security staff and mental health services. See Recommendation
A6 for more on intermediate housing units. Vera also recommends that ODOC establish weekly
multidisciplinary reviews of individuals with SMI in the units to determine if continued
placement is necessary.
Recommendation C3. Use alternative sanctions to DSU when adults in custody
with MH2, MH3, DD2, or DD3 codes commit nonviolent infractions. As ODOC works
to reduce segregation-eligible offenses, Vera urges the agency to particularly ensure that
alternative sanctions are always used when adults in custody with these mental health or
developmental disability codes commit nonviolent infractions.
Recommendation C4. Create more mental health supports in general population.
Reducing caseload sizes for QMHPs in general population would enable them to provide more
meaningful services to people there. Some caseloads are as high as 100 adults in custody per
QMHP. With such high caseloads, most QMHPs do not have the ability to do skills coaching or
provide treatment services like they can in the more specialized day treatment units (DTUs).
They often end up merely triaging and addressing the more acute cases. ODOC should examine
the feasibility of increasing mental health and correctional rehabilitation resources to give adults
in custody who have identified needs more frequent counselor and/or mental health contact.
Recommendation C5. Create a day treatment unit on the west side of the state.
Currently, both day treatment units are situated in eastern Oregon at SRCI and TRCI. Adding a
day treatment unit on the west side of the state would enable more people to benefit from the
supportive housing and services afforded by these units and reduce the number of transfers
across the state for people on the west side in need of this level of care.
Recommendation C6. Create an intermediate care housing unit on the east side of
the state. Currently, the only intermediate care housing unit is in western Oregon at OSP.
Opening an intermediate care housing unit on the east side of the state would increase ODOC’s

58

DOJ, 2016, pp. 99-101.

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capacity to provide step-down care for people releasing from the MHI or BHU and reduce
transfers across the state for people on the east side in need of this level of care.
Recommendation C7. Create an intermediate care housing unit at CCCF. This would
open up a new housing option for releasing women from the Special Housing Unit at CCF who
still need mental health care.
Recommendation C8. Continue with the planned reforms for BHU. As ODOC moves
forward with reforms, Vera recommends that the agency continually strive to allow adults in
custody assigned to that unit more freedoms and privileges. For example, once ODOC acquires
and begins using secure program chairs for treatment and classroom programming, ensure that
adults in custody have avenues for eventually moving out of those chairs into more normalized
classroom settings with regular chairs. For an example of how this might work, see the
discussion of the ITP at Clallam Bay Corrections Center in Washington State under
Recommendation B5.

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D. Racial and Ethnic Disparities
Findings
Finding D1. Black and Hispanic adults tend to be overrepresented in segregated
housing. People of color make up 26 percent of ODOC’s total population, but 34.3
percent of the segregated population. With the exception of Asian Americans, on the
snapshot date of April 1, 2015, racial and ethnic minorities were overrepresented in segregated
housing units. For instance, as shown in Figure 19 below, Hispanic adults made up 13 percent of
the total population, but 18 percent of both the IMU and ASU populations. Black adults made up
10 percent of the total population, but 17 percent of the IMU population and 15 percent of the
BHU population.
Figure 19 below shows the racial breakdown of administrative segregation units, compared to
the total population, on the snapshot date, April 1, 2015.59 This graph also includes the less
restrictive forms of segregation, MHI and AHU, for comparison.

Figure 19. Administrative Segregation by Race
100%
88%

Percent of Population

80%

75%

73%

69%

76%

60%

Asian
Black

50%

Hispanic
Indian
25%

17% 18%
1%

4%

15%
13%
3%

White

18%
5%

5%

8%
5%

0%
IMU

BHU

ASU

MHI

12%
3% 4%
1%

AHU

13%
10%
3%
1%

Total Pop

Type of Administrative Segregation

59

Vera uses the terminology employed by ODOC to describe race and ethnicity. Note that ODOC uses
the term “Indian” to describe American Indians or Native Americans and not people from India.

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Finding D2. Overrepresentation of black and Hispanic adults is particularly
evident in IMU, BHU, and ASU. As shown in the chart above, black and Hispanic people are
disproportionately housed in the more punitive forms of administrative segregation. By contrast,
these same minority groups are under-represented in the more treatment-oriented and less
restrictive special housing units, namely the Mental Health Infirmary (MHI) and Administrative
Housing Unit (AHU). For example, black people comprised 8 percent of the MHI population
and Hispanic people comprised 5 percent. For AHU, black people made up 3 percent of the
population, Hispanic people made up 12 percent, and Indian people made up 4 percent.
Finding D3. Black women are overrepresented in segregated housing. The findings
above include both men and women, but since men make up 91 percent of the total population,
it is important to look specifically at the female population. Black women made up 7 percent of
the total female population, but 16 percent of the DSU population and 20 percent of the
population in all other segregated housing.
Figure 20 below shows the racial breakdown for women in segregated housing compared to
those in general population.

Figure 20. Segregation Population vs. General Population,
Women
100%

75%
68%
84%

76%

50%

White
Indian
Hispanic
Black

11%

25%

0%

3%
5%
7%

5%
1%

GP

4%

16%

20%

DSU

Other seg housing

Asian

Finding D4. Racial and ethnic minorities tend to have longer lengths of stay in all
types of segregated housing than white people.

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Figure 21 below shows the average length of stay in all segregated housing, in days, by
race/ethnicity and gender.
Figure 21. Average Length of Stay in All Segregated Housing
by Race/Ethnicity and Gender

N

Race

Male
7,088
1,247
143
1,247
392
10,217

White
Black
Asian
Hispanic
Indian
Total

Female
873
77
12
50
33
1,145

Mean (days)
Male
Female
49.49
18.82
59.04
20.31
40.52
16.25
74.19
29.56
59.65
32.79
54.18
19.89

Median (days)
Male
Female
14
9
14
9
12
9
21
9
14
8
15
9

Part of these longer stays may be driven by DSU sanctions, given that black and Hispanic people
often received longer DSU sanctions per incident than white people. Vera’s analysis found that
white people received an average DSU sanction of 34 days, while black people received an
average of 36 days, and Hispanic people of 61 days.

Recommendations
Recommendation D1. Create a committee to study and address disproportionate
minority contact with segregated housing. Generally, racial and ethnic minorities are
overrepresented throughout the criminal justice system. In a 2015 report, the Brennan Center
for Justice provided recommendations for reducing racial and ethnic disparities in jails,
including the creation of a cross-departmental task force.60 For ODOC, creating a
multidisciplinary committee could be a valuable way to apply this idea to a correctional agency.
Such a committee could help ODOC better understand the issue, set goals for the agency,
recommend and consider changes to practices or policies, oversee implementation of any
changes, and conduct periodic reviews of data and practice.61
Recommendation D2. Closely monitor the impact of implementing the
recommendations in this report on racial and ethnic minorities. In all internal and
external reporting on ODOC’s use of segregation, include a breakdown by race.
60

Jessica Eaglin and Danyelle Solomon, Reducing Racial and Ethnic Disparities in Jails:
Recommendations for Local Practice (New York City: Brennan Center for Justice at New York
University School of Law, 2015), pp. 33-35.
61
Tasks adapted from Eaglin and Solomon, 2015, p.33.

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E. Women
Vera’s findings and recommendations regarding women at Coffee Creek Correctional Facility
(CCCF) appear below.62

Findings
Finding E1. Women comprise 8.6 percent of ODOC’s total population and 3.4
percent of the total population in segregated housing. These figures represent the totals
on Vera’s snapshot date of April 1, 2015.
Finding E2. Women serving time in DSU spend 23 hours a day, on average, in
conditions marked by isolation, idleness, and sensory deprivation. See discussion of
conditions of DSU and administrative segregation generally, above.
Finding E3. CCCF staff and administrators employ creative solutions to address
resource and space challenges, but challenges persist. During a site visit to CCCF, Vera
learned that the facility offers a number of rehabilitation programs for women, ranging from life
skills programs and parenting programs to education, work-based, and various treatment
programs. However, as the only women’s prison in Oregon, CCCF often has to rely on creative
solutions to resource and space challenges. For example, in 2015, CCCF administrators
successfully repurposed a medical examination space for programming and acquired secure
program chairs.
Finding E4. Women can remain in segregated housing longer than necessary
because of limited placement options. Moving women out of IMU or BHU can be difficult
because ODOC only operates one women’s prison, so finding housing placements can be
challenging if a woman has a history of violent behavior or conflicts with other adults in custody.
CCCF also lacks an intermediate mental health care program, so this is not a placement option
for women leaving BHU who still need an elevated level of mental health care.
Finding E5. ODOC’s administrative rules and policies do not account for gender
differences. The same policies for the male population are applied to the female population,
including responses to behavior and disciplinary procedures.

62

Several findings and recommendations pertaining to women appear in the previous two sections, C.
Mental Health and D. Racial Disparities.

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Recommendations
Recommendation E1. Ensure that women benefit from the same types of reforms
and alternatives to segregation devised for men. Establish a specific plan for
implementing the recommendations regarding disciplinary segregation and administrative
segregation in Sections A and B at CCCF.
Recommendation E2. Review ODOC’s administrative rules and policies and revise,
where necessary, to account for gender differences and trauma. As ODOC undertakes
this review, Vera recommends consulting policy guides and tip sheets available through the
National Resource Center for Justice Involved Women (NRCJIW). In particular, NRCJIW has a
policy guide that provides a step-by-step process for helping agencies think through how gender
responsive and trauma informed their policies are.63 NRCJIW also has a shorter tip sheet
adapted from this guide for jails that provides a quick roadmap for reviewing and revising
policies.64
ODOC should also consult other organizations that provide guidance on justice-involved
women, including the National Institute of Corrections and the Association of Programs for
Female Offenders.
Recommendation E3. Ensure that women who are pregnant, post-partum, or who
have recently had a miscarriage are diverted from segregated housing. If women in
these groups commit rule violations, use alternative sanctions for nonviolent infractions and
intermediate housing units for violent infractions. DOJ’s guiding principles urge agencies not to
place women in these categories into restrictive housing, and on the international level, the
United Nations Rules for the Treatment of Women Prisoners and Non-custodial Measures for
Women Offenders (known as the “Bangkok Rules”) prohibit placing pregnant women, women
with infants, and breastfeeding mothers in segregation.65 Women in these groups may be
particularly vulnerable to the harmful psychological and physical effects of segregation, and
living in segregated housing units may create barriers to accessing needed health services.66

63

Alyssa Benedict, Becki Ney, and Rachel Ramirez, Gender Responsive Discipline and Sanctions Policy
Guide for Women’s Facilities (Silver Spring, MD: The National Resource Center for Justice Involved
Women, 2014), http://cjinvolvedwomen.org/discipline-guide/ (accessed October 24, 2016).
64
Alyssa Benedict, “Jail Tip #3: Review Discipline Policies and Practices,” 2016, adapted from Gender
Responsive Discipline and Sanctions Policy Guide for Women’s Facilities, and available at:
http://cjinvolvedwomen.org/wp-content/uploads/2016/03/Jail-Tip-Sheet-3.pdf (accessed October 24,
2016).
65
DOJ, 2016, pp. 102-103; United Nations Rules for the Treatment of Women Prisoners and Noncustodial Measures for Women Offenders (the Bangkok Rules), General Assembly Resolution 65/229,
U.N. Doc. A/Res/65/229 (2011), Rule 22.
66
See American Civil Liberties Union, Worse than Second-Class: Solitary Confinement of Women in
the United States (New York: American Civil Liberties Union, 2014).

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F. Death Row
Finding
Finding F1. Adults in custody on death row status are segregated from the general
population in that they live in designated special housing units, but they are not
isolated in their cells for 23 hours a day. Services and privileges on death row mirror
those in general population to the extent possible. Some adults in custody have jobs on the tiers,
they go outside for recreation time twice a day in small groups, and they have dayroom time in
small groups as well. They are out of their cells about 25-30 hours per week. However, at the
time of Vera’s study, only one woman at CCCF was on death row status. She did not have access
to the same types of activities or congregate opportunities as the men because there were no
other women on death row status with whom she could socialize.

Recommendation
Recommendation F1. Consider moving adults in custody on death row status into
general population. Employ an assessment and classification system to determine
appropriate placements for adults in custody on death row status. Moving these adults in
custody into general population would free up space at OSP and CCCF that could be repurposed
in other ways. It would also help relieve the burden at CCCF of providing individual privileges
and dayroom space to the one woman on death row status and alleviate the isolation
experienced by that woman due to her status as the only woman on death row in Oregon.

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G. System-wide
In this section, Vera offers some system-wide findings and recommendations based on our site
visits and meetings with staff and leaders. Although these findings and recommendations are
not about segregation, per se, they either contribute to the use of segregation or speak to
challenges raised by ODOC staff about working in segregation units and managing the
populations assigned to them.

Findings
Finding G1. Mental health, crisis intervention, and behavioral modification
training are limited for ODOC security staff and correctional counselors. All ODOC
staff get four hours of basic mental health training and two hours of suicide prevention training
upon hire. Corrections officers who work in mental health special housing (e.g., the Mental
Health Infirmary, Intermediate Care Housing, and the Behavioral Health Unit) get an additional
twelve hours of training per year, which may include modules on mental health issues. Officers
who work in segregation units get an hour of additional online training related to mental health,
but the Vera team heard a consensus that officers and correctional counselors could benefit
from additional mental health training. Security staff also get some behavioral modification
training, but the extent of this training varies from year to year.
Finding G2. Training specific to managing female populations, addressing gender
differences, and understanding gender identity is limited. ODOC staff receive some
training on transgender issues related to PREA and some training on hospital escorts for
pregnant women. Staff at CCCF do not currently get any in-service training specific to managing
female populations.
Finding G3. Working in segregated housing units can be stressful and
unpredictable. In focus groups and facility meetings, staff spoke about the stresses of working
in segregated housing units and dealing with a population that can be abrasive and abusive at
times. In particular, they talked about the difficulty of managing and responding to adults in
custody with serious mental illness who are placed in segregation. Some security staff also spoke
about their struggle to supervise adults with moderate mental illness and those with personality
disorders, but who are not seriously mentally ill. Staff reported that they did not always know
how to identify behaviors that are symptomatic of mental illness versus behaviors that might
just be “acting out” or expressions of frustration. A number of staff also talked about how
important communication skills are to working successfully in segregated housing units, but
most said they were not specifically trained in those skills; they thought it was more a matter of
having the right personality and experience for the job.
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Finding G4. At almost every facility, hearings officers and staff reported that many
adults in custody commit infractions to get into DSU because they are scared to
live in their general population housing unit. Staff spoke about how sex offenders and
other unpopular or vulnerable adults in custody will often be extorted or pressured to leave their
general population housing unit by security threat groups (STGs). This also happens to STGaffiliated individuals who have conflicts within their group or with an opposing group and those
who have dropped out of STGs. Others talked about new arrivals to a facility being scared to live
in certain general population units because of STG activity. Individuals from these different
groups tend to commit infractions that result in DSU time, which in turn contributes to DSUs
filling up. Hearings officers talked about how hard it is for staff to catch the “shot callers”
ordering the extortion, but said they try to give those adults in custody the maximum DSU
sanction they can when they receive those cases.

Recommendations
Recommendation G1. Increase mental health, behavioral modification, and
communication skills training for security staff. Additional mental health and
behavioral modification training could help officers in general population units better
understand certain problem behaviors and ways to respond that de-escalate situations, which
could, in turn, help reduce the use of segregation for adults in custody with mental illness.
Crisis intervention training (CIT) and mental health first aid training or similar would
provide staff with helpful tools for managing and de-escalating crisis situations.
§ CIT is an in-depth first responder course (usually 40 hours) for law enforcement officers
that teaches how to respond and de-escalate mental health crises. It was first developed
in Memphis in the 1980s and has since spread to many police and correctional agencies.
During the course of the assessment, Vera learned that ODOC has sent one group of staff
to crisis intervention training and is working to expand CIT to staff at OSP.
§ Mental health first aid training is a basic eight-hour course that more and more law
enforcement agencies are adopting. The Pennsylvania Department of Corrections has
delivered this training to all staff in the agency, and the North Carolina Department of
Public Safety is planning to add it to annual training later this year. This is a training
designed for first responders to help them identify signs and symptoms of mental illness,
improve mental health literacy, and defuse situations before they become crises.67

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Mental Health First Aid USA, managed and operated by the National Council for Behavioral Health
and the Missouri Department of Mental Health, has a number of resources that explain mental health
first aid training, crisis intervention training, and the differences between the two courses. See
http://www.mentalhealthfirstaid.org/cs/ (accessed July 8, 2016).

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Recommendation G2. Increase training for all staff on responding to gender
differences and understanding gender identity. Increase training for CCCF staff, in
particular, on issues specific to managing female populations and trauma-informed care.
Agency-wide training on gender should encompass all gender identities, including transgender
identity, and all gender expressions, including people who are gender nonconforming.
Recommendation G3. Continue to explore ways to improve staff wellness,
particularly for staff assigned to segregated housing units. As noted in Section III,
ODOC has made staff wellness a key departmental priority. Vera supports ODOC’s efforts and
recommends considering additional ways to help staff decompress from emotionally stressful
situations, like after a verbal altercation or other incident. As noted in Recommendation B4,
ODOC staff may benefit from having access to a staff Blue Room or similar space.
Recommendation G4. Seek staff input and involvement when implementing
reforms to the use of segregation. Staff will be instrumental in ensuring that the
recommendations contained in this report are implemented in a meaningful, practical manner.
Recommendation G5. Explore deterrence-based violence reduction models and
consider piloting such a model at ODOC. Although common in the community, group
violence reduction strategies—as opposed to strategies that focus on suppression and
containment—are newer to corrections. Early applications, however, have shown promising
results that ODOC can learn from.
Operation Ceasefire
The National Network for Safe
Communities have experimented with group
Communities, which supports communities
violence intervention strategies dating back
implementing strategic interventions to reduce
to Operation Ceasefire, a gun violence
violence and provides numerous resources on
reduction effort launched in the 1990s in
deterrence-based violence reduction strategies,
Boston. This approach has since been
worked with the Washington Department of
replicated in other communities and has
Corrections beginning in 2012 to pilot a prison
been shown to reduce violence significantly.
violence intervention based on the principles
Unlike suppression and containment
of Operation Ceasefire (see box to right).68
models—traditionally used by both law
At the end of 2012, the Washington
enforcement and correctional agencies to
Department of Corrections launched
punish individuals for singular offenses—the
Operation Place Safety, which uses the
Ceasefire model is based on principles of
Ceasefire framework to combat violence at the
deterrence and recognizes that many serious
Washington State Penitentiary. DOC
offenses are motivated by group dynamics.
administrators identified three prohibited acts
68

See National Network for Safe Communities, “Prison Violence Intervention,”
https://nnscommunities.org/our-work/strategy/prison-violence-intervention (accessed July 8, 2016).

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to target for group enforcement, provided opportunities for rehabilitative programming, and
educated incarcerated people about those targeted acts, consequences for engaging in them, and
the programs available to them if they maintained clear conduct.69 In the first year of
implementing Operation Place Safety, the Washington Department of Corrections reports seeing
a 50 percent decrease in the three violent prohibited acts.70
In 2014, administrators at a prison in Pennsylvania (State Correctional Institution Forest)
worked with the Washington Department of Corrections to develop their own version of this
program called Operation Stop Violence. Though their program is still relatively new, they have
also reported a reduction in violence in the first few months.71
Recommendation G6. Implement strategies for supporting adults in custody who
use DSU as default protective custody because of fears of living in general
population. Some jurisdictions, like Washington, New Mexico, and Pennsylvania have
established missioned housing units that mix compatible populations with similar needs. ODOC
might find that model helpful for thinking through how to house people who fear for their safety
in general population. Some of the ideas contained in Recommendation A5 (regarding
enhancing supports in general population) and Recommendation B6 (regarding safe housing
options) could be helpful for these populations as well. For example, ODOC might consider
assigning peer mentors and increasing counselor contact in the first months of incarceration to
help new adults in custody with their adjustment to prison life. Pennsylvania uses peer mentors
in their Special Needs Units. An in-depth orientation at intake might also help people feel more
prepared for what to expect in prison.
Recommendation G7. Conduct a comprehensive assessment of all staffing needs
from all disciplines (security, mental health, and correctional rehabilitation).
Adjust or increase staffing resources where needs are identified. ODOC’s staffing
plan should describe staffing levels and strategies for deploying staff that will ensure adults in
custody receive adequate supervision, access to meaningful programs and services, and
appropriate levels of mental health treatment.
Recommendation G8. Measure the impact of reforms implemented to reduce the
use of segregation by creating a data tracking process, including soliciting and
incorporating feedback on reforms from staff and adults in custody. Because
segregation reform is still in its infancy nationwide, many of the strategies ODOC will
implement are promising, but not yet fully evidence-based. Measuring the impact of reform
69
See Warner, Pacholke, and Kujath, 2014, p. 2. The Vera project team also heard about this
program directly from former Washington Department of Corrections Secretary Dan Pacholke in a
conference call on March 8, 2016.
70
Warner, Pacholke, and Kujath, 2014, p. 20.
71
Warden Michael Overmyer, phone call with Vera project team, February 25, 2016.

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efforts will be imperative for building up an evidence base, tracking adherence to new policies
and practices, monitoring whether any of the changes have unintended negative consequences,
identifying successes, and making modifications to improve on the reforms.

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V. Conclusion
In recent years, a diverse range of international and national bodies, advocates, policymakers,
the U.S. Department of Justice, and corrections practitioners have called for reform of
segregation practices in correctional systems. Whether citing the potentially devastating
psychological and physiological impacts of spending 23 hours per day alone in a cell the size of a
parking space, the cost of operating such highly restrictive environments, or the lack of
conclusive evidence demonstrating that segregation makes correctional facilities safer, these
voices agree that reform and innovation are worthwhile endeavors. In 2016, many segregation
reform efforts are still in their infancy. Still, as the examples discussed in this report make clear,
there is much to learn from the ongoing work in states like Washington, New Mexico,
Pennsylvania, and Colorado.
As the Oregon Department of Corrections moves forward with implementation of reform
efforts, Vera has every confidence that the agency will learn from its peers in the field, capitalize
on its own strengths, and use these recommendations as a springboard for improving the lives of
the men and women who live and work in Oregon’s prisons.

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Appendix 1: Overview of
Oregon Department of Corrections
Information contained in this appendix is drawn from ODOC’s application for the Safe
Alternatives to Segregation Initiative and Vera’s site visits during the assessment process.
A. Medium/Maximum Facilities Holding the Majority of ODOC’s Segregation
Population
1. Oregon State Penitentiary (OSP)
OSP is Oregon’s only maximum-security prison. It is located in Salem and houses over 2,000
male adults in custody. OSP is surrounded by a 25-foot-high wall with 10 towers. OSP
participates in prison industries with Oregon Corrections Enterprises, including the furniture
factory, laundry, metal shop, and contact center. It provides a range of correctional programs
and services including education, work-based education, adult in custody work crews, and prerelease services. OSP was established in 1866 and, until 1959, was Oregon’s only prison.
Segregation at OSP:
§ Disciplinary Segregation Unit
§ Special Management Building
o Death Row
o Behavioral Health Unit
o Intermediate Care Housing1
o Mental Health Infirmary
2. Coffee Creek Correctional Facility (CCCF)
CCCF is a multi-custody prison in Wilsonville accommodating all of Oregon’s female adults in
custody (approximately 1,260). The prison has cell and dormitory housing, work programs,
skills training, treatment programs, health services, religious services, a central records unit,
and administrative areas. CCCF participates in prison industries with Oregon Corrections
Enterprises. In addition, CCCF houses the state’s intake center, which provides intake and
evaluation of all adults in custody committed to state custody by the courts. The intake center
houses approximately 400 male adults in custody. CCCF’s minimum facility opened in 2001,
and the medium facility opened in 2002.

1

Towards the end of the assessment, the Intermediate Care Housing unit moved out of the Special
Management Building in preparation for planned modifications to the Behavioral Health Unit.

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CCCF’s Special Housing Unit is one building containing the following female segregation units:
§ Death Row
§ Behavioral Health Unit
§ Disciplinary Segregation Unit
§ Intensive Management Unit
§ Administrative Segregation Unit
CCCF also has a Mental Health Infirmary.
3. Oregon State Correctional Institution (OSCI)
OSCI is a medium-security men’s prison in Salem that houses approximately 870 male adults in
custody. It provides a range of correctional services and programs including education, drug and
alcohol treatment, mental health treatment, religious services, adult in custody work crews, and
transition planning. OSCI participates in prison industries with Oregon Corrections Enterprises,
including a print shop and a contact center. OSCI was established by action of the 1955
Legislature and became fully operational on June 1, 1959.
OSCI has a disciplinary segregation unit.
4. Snake River Correctional Institution (SRCI)
SRCI is a multi-custody prison in Ontario that houses approximately 3,000 male adults in
custody. SRCI participates in prison industries with Oregon Corrections Enterprises, including a
contact center, laundry, and sign shop. SRCI specializes in incentive housing, specialized
housing, adults in custody with mental health/medical vulnerabilities, education and trades
programs, cognitive and parenting programs, and institution work programs. SRCI opened in
1991 and is the largest correctional institution in the state.
Segregation at SRCI:
§ Intensive Management Unit
§ Administrative Segregation Unit
§ Disciplinary Segregation Unit
5. Two Rivers Correctional Institution (TRCI)
TRCI is a multi-custody prison in Umatilla that houses approximately 1,800 male adults in
custody. TRCI participates in prison industries with Oregon Corrections Enterprises, including
institution and industrial laundry, mattress manufacturing, and sewing. Other institution work
programs include reparation and cleaning of irrigation ditches, maintenance of local baseball
fields, and work with local cities and the Hermiston School District. The facility provides a range
of correctional programs and services including education, the Rehabilitation of Offenders and
Canines program, religious services, and behavioral health services. TRCI opened in 2000.

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Segregation at TRCI:
§ Disciplinary Segregation Unit
§ Administrative Housing Unit
6. Eastern Oregon Correctional Institution (EOCI)
EOCI is a medium-security prison in Pendleton that houses over 1,600 male adults in custody.
The institution is known for its Oregon Corrections Enterprises industries, including a garment
factory that produces Prison Blues©, whose products are sold in and outside the United States.
Other industries are its embroidery and laundry facilities. EOCI provides a range of correctional
programs and services including education, drug and alcohol treatment, mental health
treatment, religious services, and adult in custody work crews. The buildings that make up EOCI
were constructed in 1912 and 1913 and were originally used as a state mental hospital. After two
years of renovation, EOCI received its first adults in custody in June 1985.
EOCI has a disciplinary segregation unit.

B. Minimum Facilities
1. Columbia River Correctional Institution (CRCI)
CRCI is a minimum-security facility that houses approximately 595 male adults in custody who
are within four years of release. Located in the largest metropolitan area of the state, this facility
is focused on cognitive programming, work programs, and preparing adults in custody for
return to the community. CRCI is home to a 50-bed cognitive restructuring Alternative
Incarceration Program (AIP). Individuals who successfully complete this 180-day in-prison
program are released to the community for a 90-day transitional leave period. Individuals who
successfully complete the transitional leave period are granted a reduction in their sentence and
move to post-prison supervision.
2. Deer Ridge Correctional Institution (DRCI)
DRCI is a multi-custody facility located four miles east of Madras in central Oregon. This men’s
prison contains 644 minimum-security beds and 1,223 medium-security beds. The minimum
facility began receiving adults in custody in September 2007. The medium facility has not
received adults in custody due to cost saving measures. DRCI provides a range of correctional
programs and services including education, drug and alcohol treatment, mental health
treatment, cognitive programs, and adult in custody work crews.
3. Mill Creek Correctional Facility (MCCF)
MCCF is an unfenced, minimum-security prison in Salem that houses approximately 290 male
adults in custody who are within four years of release. The facility concentrates on work
opportunities, most of which are in the form of work crews contracting with state agencies, local

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organizations, and private industries within a 60-mile radius of Salem. MCCF opened in 1929 as
the Farm Annex of the Oregon State Penitentiary, housing 50 adult male offenders. The Farm
Annex provided all of the milk, eggs, meat, fruit, and vegetables for the Oregon State
Penitentiary and the State Hospital. The main building (as well as many of the out buildings that
made up the farm) still stands today and, at 81 years old, it makes for the second oldest prison in
the state.
4. Powder River Correctional Facility (PRCF)
PRCF is a minimum-security prison in Baker City that houses approximately 366 male adults in
custody who are within four years of release. PRCF serves as a transition and re-entry facility
and is focused on cognitive programming, work programs, and preparing adults in custody for
return to the community. PRCF is home to the 128-bed New Directions (Drug and Alcohol
Treatment) Alternative Incarceration Program. Individuals who successfully complete this 180day in-prison program are released to the community for a 90-day transitional leave period.
Individuals who successfully complete the transitional leave period are granted a reduction in
their sentence and move to post-prison supervision. PRCF opened in November 1989.
5. Santiam Correctional Institution (SCI)
SCI is a minimum-security prison in Salem that houses approximately 440 male adults in
custody who are within four years of release. The facility concentrates on work opportunities,
most of which are in the form of work crews contracting with state agencies, local organizations,
and private industries within a 60-mile radius of Salem. SCI provides a range of other
correctional programs and services including education, transition programs, and religious
services. The building that is now SCI was constructed in 1946 and originally was used as an
annex to the Oregon State Hospital for mental health patients. Over the years it was used for a
variety of correctional purposes until, in 1990, it opened as SCI.
6. Shutter Creek Correctional Institution (SCCI)
SCCI is a minimum-security prison in North Bend that houses approximately 286 male adults in
custody who are within four years of release. SCCI serves as a transition and re-entry facility and
is focused on cognitive programming, work programs, and preparing adults in custody for
return to the community. Adults in custody work on the institution site in the kitchen and dining
hall, warehouse, receiving and discharge, laundry, and prison grounds. Adults in custody also
work on outside crews, primarily with the Department of Forestry, providing services
throughout the year as trained wildland firefighters. Originally an Air National Guard radar
station, the facility was converted into a prison in 1990.
7. South Fork Forest Camp (SFFC)
SFFC is minimum-security work camp that houses approximately 200 male adults in custody
who are within four years of release. Part of SFFC’s mission is to supply a ready work force to

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combat forest or wild fires throughout the state. Crews provide critical support for statewide fire
operations, recreation, and reforestation, as well as provide support for special projects such as
sign making, metal fabrication, and tool or equipment repair. SFFC was established in 1951 and
is a satellite facility to CRCI and managed jointly with the Oregon Department of Forestry.
8. Warner Creek Correctional Facility (WCCF)
WCCF is a minimum-security prison in Lakeview that houses approximately 486 male adults in
custody who are within four year of release. WCCF provides a range of correctional programs
and services including education, transitional programs, religious services, and work
opportunities crews. WCCF has a contact center on site through Oregon Corrections Enterprises.
WCCF opened in September 2005 and is Oregon’s newest operating prison. It received the State
Energy Efficiency Design (SEED) award in May 2008 for its progress in design efficiency. The
most energy-efficient element at WCCF is the use of geothermal energy, providing 100 percent
of the hot water to the facility.

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Appendix 2: Summary of Recommendations
A. Disciplinary Segregation
Recommendation A1. Significantly reduce the number of segregation-eligible infractions in
the Major Violation Grid.
Recommendation A2. Reduce the maximum length of stay in DSU.
Recommendation A3. Limit the use of prehearing DSU to only adults in custody who pose a
serious threat to safety or security.
a. Reform procedures regarding temporary placement in DSU before a disciplinary
hearing has been held.
b. Reform procedures regarding placement in DSU on administrative hold status.
c. Collect and track data on how often DSU is used for temporary placement and
administrative hold, to ensure policies are being followed.
Recommendation A4. Review instances where DSU has been used as a response to minor
offenses and correct issues leading to that practice.
Recommendation A5. Enhance supports, structured activities, and programming in general
population to keep people from going into DSU, particularly high-risk groups (such as young
adults and those with identified mental health needs).
a. Examine correctional case management practices and ensure that adults in custody
are receiving appropriate levels of contact and supervision from their counselors.
b. Examine strategies that may help adults in custody alleviate stress and reduce their
likelihood of breaking the rules.
c. Expand privileges and programming in general population.
Recommendation A6. Create intermediate housing units where adults in custody can be
placed after a DSU stay if it is determined, through a multidisciplinary review process, that they
are not ready yet for general population but do not require the level of secure supervision
provided in the intensive management unit (IMU).
Recommendation A7. Discontinue the practice of imposing additional punishments on
adults in custody sanctioned to DSU.
Recommendation A8. Revise policy regarding loss of contact visits as a sanction. Contact
visits should be restricted to basic visits only when there is a pressing concern about safety and
security.

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Recommendation A9. Eliminate loss of segregation yard time as a sanction in DSU.
Recommendation A10. Reduce the number of collateral consequences that flow from a
sanction to DSU.
Recommendation A11. Discontinue use of the Adjustment to Final Order form and grid as
the mechanism for initiating reviews and time reductions for adults in custody in DSU.
Implement a more meaningful automatic review process that is triggered at regular intervals
(e.g., every seven days), and establish new guidelines on allowable time reductions.
Recommendation A12. Strengthen the procedures governing conduct orders to improve the
fairness and effectiveness of informal sanctions. Communicate to staff and adults in custody
how and when conduct orders will be used.
a. Institute a detailed response matrix to ensure that conduct orders are used and applied
fairly, consistently, and progressively.
b. Ensure that behavioral expectations and consequences for misbehavior are understood
by staff and adults in custody.
c. Institute procedures requiring staff to discuss the reason for the conduct order with the
adult in custody being sanctioned.
d. Establish meaningful oversight of the sanctions imposed to ensure that sanctions are
fairly applied and proportionate.
Recommendation A13. Improve conditions of confinement in DSU.
a. Allow more opportunities for out-of-cell time and congregate activity.
b. Create more opportunities for productive activities in-cell.
c. Create Blue Rooms or de-escalation rooms in DSU units.
d. Examine the physical space of DSU cells and recreation spaces and identify changes that
can be made to increase size and natural light.
e. Explore the impact of double-celling on the safety and well-being of adults in custody
housed in double-celled DSUs.
f. Ensure that qualified mental health professionals (QMHPs) or health services
practitioners are doing in-person mental health assessments (and not just chart reviews)
within 24 hours of a person’s placement in DSU.
g. Allow adults in DSU telephone privileges to speak with family and other support people.
h. Increase the number and length of basic visits afforded to adults in custody in DSU who
have demonstrated positive behavior.
Recommendation A14. Reform the use of DSU at minimum-security facilities.
Recommendation A15. Collect and track data on ODOC’s use of disciplinary segregation.

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B. Administrative Segregation
Recommendation B1. For adults in custody in DSU who have been flagged for possible IMU
placement, conduct evaluations for placement in IMU sooner, so those individuals do not spend
months in DSU before gaining access to IMU programming.
Recommendation B2. Review adults in custody placed in IMU at shorter intervals.
Recommendation B3. Implement instructor-led programming in a classroom setting in IMU.
Recommendation B4. Create more Blue Rooms or other types of de-escalation spaces where
adults in custody living in segregated units can spend time.
Recommendation B5. Create a structured reentry process and/or step-down units for adults
in custody transitioning out of long-term segregation. Ensure that adults in custody are never
released directly to the community from segregation.
Recommendation B6. Conduct a comprehensive examination of safe housing options across
ODOC for adults in custody releasing from long-term administrative segregation.
Recommendation B7. Consider redesigning ASU to more closely resemble AHU.
Recommendation B8. Improve conditions of confinement in IMU and ASU.
a. Allow more opportunities for out-of-cell time and congregate activity.
b. Create more opportunities for productive activities in-cell.
c. Expand use of Blue Rooms or de-escalation rooms (See Recommendation B.4).
d. Examine the physical space of IMU and ASU cells and recreation spaces and identify
changes that can be made to increase size and natural light.
e. Explore the impact of double-celling on the safety and well-being of adults in custody
housed in double-celled IMUs.
f. Increase access to qualified mental health professionals (QMHPs).
g. Increase access to telephone privileges to speak with family and other outside support
people.
h. Seek ways to expand and incentivize visiting privileges for adults in custody in IMU and
ASU.
Recommendation B9. Resolve inconsistencies across the Oregon Administrative Rules and
departmental policies governing types of segregated housing.

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C. Mental Health
Recommendation C1. Enact policies that prohibit placing people with serious mental illness
(including those with the developmental disability code of DD3) and neurodegenerative diseases
in any form of segregated housing that limits meaningful access to social interaction,
environmental stimulation, and therapeutic programming.
Recommendation C2. Enact restrictions on placing adults in custody with MH3 and DD3
codes in DSU, and designate a small number of beds in newly established intermediate housing
units for adults in custody with MH3 or DD3 codes who commit violent infractions.
Recommendation C3. Use alternative sanctions to DSU when adults in custody with MH2,
MH3, DD2, or DD3 codes commit nonviolent infractions.
Recommendation C4. Create more mental health supports in general population.
Recommendation C5. Create a day treatment unit on the west side of the state.
Recommendation C6. Create an intermediate care housing unit on the east side of the state.
Recommendation C7. Create an intermediate care housing unit at CCCF.
Recommendation C8. Continue with the planned reforms for BHU.

D. Racial Disparities
Recommendation D1. Create a committee to study and address disproportionate minority
contact with segregated housing.
Recommendation D2. Closely monitor the impact of implementing the recommendations in
this report on racial and ethnic minorities.

E. Women
Recommendation E1. Ensure that women benefit from the same types of reforms and
alternatives to segregation devised for men.
Recommendation E2. Review ODOC’s administrative rules and policies and revise, where
necessary, to account for gender differences and trauma.

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Recommendation E3. Ensure that women who are pregnant, post-partum, or who have
recently had a miscarriage are diverted from segregated housing.

F. Death Row
Recommendation F1. Consider moving adults in custody on death row status into general
population.

G. System-wide
Recommendation G1. Increase mental health, behavioral modification, and communication
skills training for security staff.
Recommendation G2. Increase training for all staff on responding to gender differences and
understanding gender identity.
Recommendation G3. Continue to explore ways to improve staff wellness, particularly for
staff assigned to segregated housing units.
Recommendation G4. Seek staff input and involvement when implementing reforms to the
use of segregation.
Recommendation G5. Explore deterrence-based violence reduction models and consider
piloting such a model at ODOC.
Recommendation G6. Implement strategies for supporting adults in custody who use DSU as
default protective custody because of fears of living in general population.
Recommendation G7. Conduct a comprehensive assessment of all staffing needs from all
disciplines (security, mental health, and correctional rehabilitation). Adjust or increase staffing
resources where needs are identified.
Recommendation G8. Measure the impact of reforms implemented to reduce the use of
segregation by creating a data tracking process, including soliciting and incorporating feedback
on reforms from staff and adults in custody.

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