VII. Inhumane Prisons

Cuba fails to meet basic international standards regarding the treatment of prisoners. Conditions are abysmal for common and political prisoners alike, with overcrowded cells, unhygienic and insufficient food and water, and inadequate medical treatment.

Under international human rights law, prisoners retain their human rights and fundamental freedoms, except for restrictions on rights that are required by incarceration, and the conditions of detention should not aggravate the suffering inherent in imprisonment.[222] But in Cuba, prisoners who attempt to exercise their rights are severely reprimanded. Political prisoners who criticize the government, document abuses, report violations, or engage in any activity deemed “counterrevolutionary” suffer consequences that are harmful to their physical and psychological health.

Political prisoners who speak out are routinely subjected to extended periods of solitary confinement, harassment, and beatings. They are denied access to medical treatment in spite of chronic health problems rooted in, and exacerbated by, abysmal prison conditions. Family visits and other forms of communication are arbitrarily refused. Human Rights Watch documented three cases in which political prisoners were deliberately moved to close quarters with prisoners infected with tuberculosis, despite the fact that they themselves were not infected. Compounding these widespread and systematic abuses is the fact that prisoners have no effective complaint mechanism through which to seek redress, creating an environment of total impunity.

Cuba ratified the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment on May 17, 1995, which states that no circumstances may be used to justify the use of torture, or cruel, inhuman, or degrading treatment, and requires member states to take steps to prevent it. The convention obligates states to take measures to allow for complaints in cases of torture and cruel, inhuman, and degrading punishment, and to hold accountable those who carry out such acts.[223]

Restricted Visits and Correspondence

Prison authorities arbitrarily suspend visits from family and friends, ban phone calls, and intercept letters to political prisoners who express political views or challenge prison conditions. Cuban law states that prisoners have the right to receive visits and maintain correspondence with non-prisoners,[224] privileges also provided for by international human rights standards.[225] Yet political prisoners informed Human Rights Watch that these rights were routinely suspended when prisoners exercised dissent, such as participating in hunger strikes, reporting abuses by guards, chanting pro-human rights or anti-government slogans, or refusing to wear prison uniforms. When authorities cancel visits, they not only deny prisoners critical emotional support, but also deprive them of food and medicine, as family members are allowed to bring provisions to supplement the inadequate rations and medicine provided by prison officials.

Political activist and human right defender Alexander Santos Hernández said authorities repeatedly denied him family visits during the two years he spent in Cuba Sí! prison in Holguín from 2006 to 2008. When Santos, who was serving time for “dangerousness,” asked prison officials for a reason:

They said that you had to be on your best behavior—salute the military, dress as a prisoner, go to [pro-government] events in the prison, go to “rehabilitation” classes—that visits were like a bonus and would require the signature of the rehabilitation department. Since we weren’t doing any of these things, they wouldn’t allow us visitors.[226]

Lázara Bárbara Sendiña Recardesaid authorities repeatedly cancelled her visits with her husband, political prisoner Hugo Damián Prieto Blanco when he was being held in Combinado del Este prison in Havana in 2008 and 2009.[227] Prieto had been held in at least two other prisons (Canaleta and Morón), his wife said, including both of which had arbitrarily suspended visits. René Velásquez González, the son of political prisoner Ramón Velásquez Toranzo, said prison authorities would only allow him to visit his father in 2007 on the condition that he try to convince him to abandon a hunger strike.[228]

Family members of political prisoners said authorities routinely failed to notify them when visits had been cancelled. Because the journey to prisons is often a long and costly one for relatives, due to transportation costs and food purchases for inmates, the practice places an unnecessary burden on family members. Lázara Bárbara Sendiña Recarde told Human Rights Watch that on several occasions authorities did not notify her that her visits with her husband had been cancelled until she arrived at the prison.[229]

Arbitrary Prison Transfers

Under Fidel Castro, Cuban authorities consistently sent political prisoners to prisons far from their families, despite the existence of prisons significantly closer to their homes. After the March 2003 crackdown, for example, Manuel Vázquez Portal—a journalist from Havana who was sentenced to 18 years in prison—was imprisoned more than 750 km east of his home, in Santiago de Cuba’s Boniato prison. Meanwhile, Jesús Mustafá Felipe—one of the organizers of the Varela Project from Santiago, who was sentenced to 25 years in the same crackdown—was sent roughly 750 km in the other direction, to Havana’s Combinado del Este prison. This tactic seemed designed to deliberately increase hardship for prisoners and their families, making visits more costly and difficult, and consequently less frequent. The practice contravenes international standards, which state that prisoners should be kept reasonably close to their places of residence.[230]

Under Raúl Castro, the government has reduced its use of this tactic, imprisoning new political prisoners in facilities closer to their families, and moving some of the prisoners who were jailed in the 2003 crackdown closer to their homes.[231] Interviews with a range of political prisoners arrested under Raúl Castro, however, suggest the use of a new tactic: moving prisoners between different units within prisons. Five prisoners sentenced since July 2006 said they were subject to frequent, arbitrary moves from one prison unit to another, increasing their risk of being attacked in large cells by individuals convicted of violent crimes, they said.

Human rights defender Juan Luís Rodríguez Desdín said he was moved to seven different “companies” (companías)—groups of 80 to 100 prisoners—from 2006 to 2008, when he was imprisoned for “dangerousness.”[232] Political activist Digzan Saavedra Prat said he was transferred to five different units during the year he was in prison (2008).[233] Both men told Human Rights Watch that political prisoners were the only ones who were transferred between units, suggesting the strategy was specifically designed to target those serving time for expressing dissent.

Exposure to Tuberculosis

In three separate instances—each of which occurred in a different prison at a different time—political prisoners said officials moved them in close proximity to prisoners with tuberculosis. In all three incidents, political prisoners were moved out of cells where they were not exposed to TB, and were given no explanation for their transfer. The cases suggest a deliberate effort on the part of authorities to expose political prisoners to a highly contagious and potentially deadly disease. They also contravene international standards, which call for medical officers to see to the segregation of prisoners with infectious and contagious conditions.[234]

The World Health Organization (WHO) has stated that overcrowding, poor nutrition, poor ventilation, and limited access to insufficient healthcare make prisons breeding grounds and incubators for TB.[235]  The TB-incidence rate in prisons can be more than 30 times higher than that outside prisons. Prisoners with serious health problems, such as those endemic to Cuban prisons, are more susceptible to TB and suffer more adverse health effects, including death. The mortality rate for TB in prisons can be five times higher in prisons than outside.[236]

In 2008, dissident Eduardo Pacheco Ortízwas serving a two-year sentence for “dangerousness” in Canaleta prison in Ciego de Ávila, when he said he was suddenly transferred to a different unit.

I was very surprised because the prisoners told me when I arrived there, “Here they don’t bring in or take out anyone because we’re in quarantine here.” And I asked, “for illness?” And they said, “For tuberculosis.” It was very suspicious that they put me in that place where there were 70-something cases of tuberculosis.[237]

Pacheco said the unit to which he was transferred consisted of roughly 75 prisoners, who shared an overcrowded, single cell with poor ventilation and two squat toilets—conditions that are ideal for spreading the virus. To his knowledge, he was the only person in the unit who was not infected with tuberculosis.

Two members of the group of 75 political prisoners arrested in 2003—both of whom were already suffering from serious medical ailments—said that they were transferred to cells with prisoners infected with TB. Dr. Alfredo Pulido López told his wife he was transferred into a TB-quarantined cell in Kilo 7 prison in Camagüey in 2007.[238] And in 2005, Normando Hernández Gonzalezsaid he was assigned to a cell in Kilo 5½ prison in Pinar del Río with a prisoner who had TB.[239] Neither political prisoner had been diagnosed with TB before his move, and they were given no explanation for the transfers. Because Pulido and Hernández were suffering from severe and chronic health problems at the time of their exposure, both were at particular risk of being infected.

As a result of their exposure, both Pulido and Hernández had to be given extended medical treatment for TB, consisting of an aggressive regimen of antibiotics, which aggravated some of their existing health problems. As Hernández wrote about his treatment in an open letter from prison in September 2005:

The two pills I took from Monday to Friday for six months worsened my gastrointestinal diseases, my gastritis became a chronic gastroduodenitis, my small intestine inflammation also became chronic, and I began to experience problems in my colon, diagnosed by the specialist in gastroenterology Miraida.[240]

Unhygienic Conditions

Across Cuba’s wide range of prisons, conditions routinely fail to meet requirements set by Cuban law and international standards.[241] Cuban law says the state is required to provide those deprived of liberty with “articles of basic necessity” and “promote better prison conditions.”[242] However, former prisoners and family members of current prisoners uniformly said that food was insufficient and unhygienic, and water was contaminated; that cells were overcrowded, lacked proper ventilation, and were infested with rodents, mosquitoes, and other insects; and that bedding was virtually non-existent, with prisoners routinely sleeping on the floor. These poor conditions affect all prisoners.

Dozens of prisoners and their family members said it was not uncommon for as many as 100 inmates to share a single cell with only one toilet. International standards state that different categories of prisoners should be held in separate jails or at least in different quarters,[243] but, as already noted, political prisoners said authorities routinely flouted this norm. Overcrowding often leads to or exacerbates other problems, including unhygienic living conditions, poor health, and a lack of privacy. The European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) has found that:

All of the services and activities within a prison will be adversely affected if it is required to [hold] more prisoners than it was designated to accommodate; the overall quality of life in the establishment will be lowered, perhaps significantly. Moreover, the level of overcrowding in a prison, or in a particular part of it, might be such as to be in itself inhuman or degrading from a physical standpoint.[244]

Eduardo Pacheco Ortíz described the conditions in Canaleta prison in Ciego de Ávila, where he was a political prisoner for “dangerousness”: “Each cell should fit 60 people, but in most cases there are 80 people, and there are times that there aren’t even two toilets. The toilets are... spaces with a hole to put your feet; there is not even any disinfectant.”[245] In a March 2009 telephone conversation from prison with a local human rights defender, political prisoner Hugo Damián Prieto Blanco said that in January 2009—when he was being held in Combinado del Este prison in Havana—the prison had no water for an entire week. As a result, prison officials had to ration water. “We were thirsty, and we did not have water to bathe ourselves or flush the toilets,” Prieto said.[246]

Iván HernándezCarrillo, a journalist who has been serving a 25-year sentence since 2003 and currently is being held in Guanajal prison in Villa Clara, told his mother during visits that the food he was provided was scarce and in a state of decomposition, and that eating it gave him severe stomach pains. He also said the prison’s water supply was contaminated, and that he had repeatedly contracted parasites. Hernández was one of many prisoners in his cell unit of 50 prisoners who was suffering from a staph infection and skin rashes, a problem he attributed to the unclean conditions and all of the cellmates sharing a single toilet.[247] Víctor Yunier Fernández Martínez, a political activist who was moved to three prisons during three years of a “dangerousness” sentence, said the food and water in all of the prisons gave him parasites and bacterial infections.[248]

Unhygienic conditions can contribute to heightened rates of disease and death in prison, and have been found to violate protections against cruel, inhuman, or degrading treatment, as well as rights to life, health, and dignity.[249]

Health Problems and Inadequate Medical Treatment

The Cuban Criminal Code guarantees all detainees the right to medical care in cases of need,[250] but political prisoners said they were routinely denied treatment for serious medical problems, many of which emerged over the course of prolonged imprisonment. They also said that poor prison conditions—which produced and then exacerbated such health problems—were neither monitored nor remedied, as international standards demand.[251] In particular, political prisoners said they were refused medical treatment as punishment for their previous “counterrevolutionary” activities or for voicing dissent within prison.

Under international human rights law prisoners, like all other persons, enjoy the right to the highest attainable standard of health, which means that prison authorities should take practical measures to protect the physical integrity and the health of persons who have been deprived of their liberty. Failure to provide adequate health care or medical treatment to a detainee in prison may contribute to conditions amounting to inhuman or degrading treatment.

States have an obligation to ensure access to health facilities, goods, and services to all persons, including prisoners, without discrimination on the basis of their political or other status.  Governments also have obligations to “refrain from denying or limiting equal access for all persons, including prisoners or detainees to preventive, curative, and palliative health services,” and to abstain from “enforcing discriminatory practices as state policy.”[252]

Every former political prisoner and family member of a current prisoner we spoke with said that detainees suffered serious health ailments as a result of the substandard conditions, and that medical treatment was inadequate or nonexistent. Dr. Alfredo Pulido López was a healthy 43-year-old man when he was arrested in the March 2003 crackdown and sentenced to 14 years in prison for writing articles that were critical of the Cuban government. By August 2004, his wife Rebeca Rodríguez Souto said, he started experiencing stomach ailments and manifested the early signs of osteoporosis. In the following months, he experienced his first migraines, a significant loss of weight, hypoglycemia, and anxiety problems. With time, the problems mounted. Pulido had earned his title as a dentist, but by the second year of his detention, due to poor nutrition and lack of dental care, he started losing teeth. Medical check-ups were rare and inadequate, his wife said, the doctors repeatedly failing to prescribe any effective treatments for his ailments. Then came the onset of liver problems, insomnia, and the rapid deterioration of Pulido’s vision, Rodríguez said. As of October 2009, Pulido was still being held in Kilo 7 prison in Camagüey, where he was suffering from 17 different chronic health problems.[253]

Dozens of former political prisoners and family members of current political prisoners say that medical check-ups are not provided, even when prisoners manifest serious illnesses. Alexander Santos Hernández, a political activist and human rights defender from Holguín, said that shortly after being sent to Cuba Sí! prison in Holguín in 2006 for “dangerousness,” his face filled with painful pustules. It was an ailment he had never experienced before, and one he attributed to the unsanitary conditions, contaminated water, and poor hygiene in the prison. He said he repeatedly asked to see a doctor, but that prison officials ignored his requests. Left with no other options and experiencing serious pain, he undertook a hunger strike to demand a medical exam. Prison authorities waited until he had fasted for 23 days before they allowed him to see a doctor, Santos said.[254]

Julio Antonio Valdez Guevara, one of the 75 political prisoners arrested in 2003, said he suffered the onset of serious kidney problems within months of being imprisoned. He told Human Rights Watch that in January 2004 he experienced a severely adverse reaction to an injection he was given in Matanzas’s Canaleta prison:

I was convulsing, and a doctor said to the head [of the prison], “He is very ill, his heart is dilated and his blood pressure is at 200 and something, his life is at risk. He must go to a hospital.” And the prison head said, “You know that he is not an ordinary prisoner. Until I have authorization from Havana, I cannot move him.”[255]  

Valdez Guevara said that, in spite of his critical condition and the advice of the prison’s doctor, he was returned to his cell, where his condition worsened and he suffered considerable pain.

Such failures to provide timely medical attention may constitute inhuman or degrading treatment, as they unnecessarily exacerbate the suffering of prisoners.[256]

Despite signs that prison conditions aggravate the illnesses of all prisoners, doctors and prison officials consistently fail to ensure that harmful conditions are improved, or to move sick prisoners to facilities less likely to exacerbate their illnesses. This lack of oversight falls foul of international standards requiring that prison medical officials report cases in which prisoners’ health will be harmed by continued imprisonment; that medical officials regularly inspect prisons and alert prison officials to substandard conditions; and that prison officials take action to remedy the shortcomings.[257] The combination of lack of treatment and unchanged conditions described in testimonies collected by Human Rights Watch suggests a deliberate disregard for the health of prisoners.

International standards state that records of prisoners’ medical examinations should be kept and that prisoners should have access to their records,[258] yet political prisoners and their families said that they were repeatedly denied access to information about their health. Although such records should not be shared with family members without patients’ prior consent, our interviews confirmed that the issue was not one of consent. Political prisoners said they repeatedly requested medical information for themselves and for their families, only to be denied.  The lack of information adds to the emotional hardship of family members, who find themselves uninformed and powerless as they witness the decline in health of a loved one.

A boxer and physical fitness instructor, Ariel Sigler Amaya was in excellent shape when he was arrested in the March 2003 crackdown. The leader of an unofficial political group, he was sentenced along with his brother, Guido Sigler Amaya, to 20 years in prison for “acts against the independence or territorial integrity of the state.”[259] By 2009, he said, his illnesses included “chronic gastritis, pulmonary emphysema, chronic pharyngitis, a bacterium, and gallbladder stones.”[260] Having been moved between at least four different prisons and two military hospitals, at 47 years old Arielcan no longer walk, and is now confined to a wheelchair. “He already lost feeling in his legs—they are so thin that you can see the bones,” said his brother, Juan Francisco Sigler Amaya, following a February 2009 visit to the military hospital where Ariel was being held. “He doesn’t have mobility in his shoulders and arms. He has lost more than 100 pounds.... He is unrecognizable.”[261] 

In spite of Ariel’s deteriorating condition, his family members said they have consistently been denied information about his health. They have not been allowed to meet with doctors or see any of his medical records, his brother said. As a result, Ariel’s family and a small group of supporters held a peaceful protest on February 18, 2009, outside of the hospital where he was being treated to demand that he be given a full medical examination and that he and his family be informed of the results. According to his brother, the protest was forcibly broken up by State Security agents, who beat Ariel’s wife and 15-year-old son without provocation.[262]

Harassment and Beatings

Human Rights Watch documented dozens of cases in which prison officials physically abused, harassed, and humiliated political prisoners in jails. Such attacks often were compounded by prison authorities’ subsequent denial of medical treatment to the victims. This treatment directly violates Cuban law, which states that, “The suspended individual cannot be subjected to corporal punishment, nor is it permissible to use any measure against him which signifies humiliation or would infringe upon his dignity.”[263] It also contravenes the Universal Declaration of Human Rights and other international standards prohibiting the use of cruel, inhuman, or degrading treatment or punishment.

Political prisoner Normando Hernández Gonzáleztold his wife that in March 2006, without provocation, the “re-educator” in prison Kilo 5½ in Pinar del Río twisted his arms behind his back, hit him on the backs of his legs, and threw him down a flight of stairs. Hernández said he was then placed in solitary confinement for seven days and denied medical care for the injuries he sustained in the fall.[264] Hernández, a journalist,is serving a 25-year sentence for “acts against the independence or territorial integrity of the state.”

Raymundo Perdigón Brito, another journalist, was beaten repeatedly by guards in January and February 2008 for complaining about conditions in Nieves Morejón prison in Sancti Spíritus, according to his sister. Perdigón was sentenced to four years in prison for “dangerousness” in December 2006. In one of the incidents, his sister told Human Rights Watch, “[the guards] brought him with his hands shackled to a place known as the ‘tunnel’ and savagely beat him. He fell unconscious and was taken to a punishment cell for ten days.”[265] In 2006, prison authorities in Villa Clara’s Guanajal prison beat dissident Iván Hernández Carrillo and called him a “black monkey” (Hernández is Afro-Cuban). Two years later, the internal prison director (jefe del interior) of the same prison told Hernández that he controlled all of the common prisoners, and that they would do whatever he told them to do, including attacking Hernández.[266]

Abuse is not limited to physical attacks. Several political prisoners spoke of being forced to commit degrading acts, as well as of suffering verbal and psychological abuse. Journalist Alfredo Pulido López said that, in 2008, guards in Kilo 7 prison in Camagüey stripped off his clothes and forced him to walk down the corridor between prisoners’ cells naked, while authorities made lewd jokes about his wife.[267]

Solitary Confinement

Prison authorities routinely subject political prisoners to solitary confinement, either arbitrarily imposing it on political prisoners or using it as a means of reprimanding dissent within the prison system.

International standards state that “punishment by placing [the prisoner] in a dark cell, and all cruel, inhuman or degrading punishments shall be completely prohibited,”[268] and experts have concluded that prolonged solitary confinement may rise to the level of cruel, inhuman, and degrading treatment or torture.[269] Solitary confinement is detrimental to mental and physical health, and therefore international standards require that it “be used only in exceptional circumstances or when absolutely necessary,” and that it last for the shortest amount of time possible.[270]

However, nearly all of the political prisoners interviewed by Human Rights Watch said they were subjected to solitary confinement at some point in their detention. They described cramped, squalid cells without bedding—some in total darkness, others with permanent bright lights—where they were deprived of all human contact. They said they were repeatedly denied visits by medical professionals, a further contravention of international standards, and provided with rotting, inadequate food at irregular intervals.[271] 

From 2006 to 2009, political activist Víctor Yunier Fernández Martínez was imprisoned in 1580 prison in Havana and Canaleta prison in Ciego de Ávila, where he said authorities repeatedly placed him in solitary confinement for days, weeks, and even months at a time as punishment for his acts of dissent, which included voicing criticism of the Cuban government and engaging in hunger strikes. He told Human Rights Watch:

The cells are one meter or one-and-a-half meters wide by two meters long. You sleep during the day on a concrete platform and at night you get a mattress, which is removed at daybreak. You are not allowed to have any belongings, and the food is terrible.... Some cells have a little window, others none. Some cells have light, others don’t.[272]

In January 2007, journalist Ramón Velásquez Toranzo was sentenced to three years for “dangerousness” and was sent to El Típico provincial prison in Las Tunas. According to his daughter, he was immediately placed in solitary confinement for refusing to eat. She said he was stripped of his clothes and placed in a tiny cell, which flooded with water when it rained and had no bedding. In another case, Yordis García Fournier spent three consecutive months in solitary confinement since he was sentenced in September 2008 for refusing to cooperate with prison authorities, according to his brother.[273]

Political prisoner Manuel Vázquez Portal said he was immediately placed in solitary confinement when he arrived at Boniato prison in Santiago de Cuba in 2003. As he described the conditions:

Punishment cells are one by two meters long, with a bunk made of corrugated slats with a wooden plank of pressed sugar cane chuff, a dirty and old cotton wool mattress. They didn’t give us sheets, towels.... There wasn’t water, just a “Turkish” toilet with a sickening odor. There was a window with bars an inch in diameter. Everything got in—rain, insects, rodents, rats. It was a filthy cell.... I remained there from April 25, 2003, to September 1st, when I began my first hunger strike. There was no access to doctors.... We all got lung and skin diseases.[274]

According to Vázquez, six other political prisoners who arrived at Boniato prison at the same time—men who were also sentenced in the 2003 crackdown—were immediately placed in similar solitary confinement. One of them was Pedro Pablo Álvarez Ramos—a trade unionist who led an unrecognized, small union— who described conditions identical to those recounted by Vázquez Portal.[275]

Lack of Adequate Monitoring and Complaint Mechanisms

The Cuban prison system lacks adequate oversight mechanisms and fails to provide effective means for prisoners to voice complaints. Officials do not remedy abuses that are brought to their attention, allowing abysmal conditions to persist while those responsible benefit from total impunity. Such failings violate Cuba’s international obligations— particularly as Cuba is a party to the Convention against Torture—to offer effective and confidential remedies to victims of human rights abuses.[276]

Nevertheless, the Cuban government publicly maintains that its prisons have an effective monitoring and complaint system, informing the UN in March 2009:

Inmates are entitled to submit complaints and requests to the authorities and to receive a proper response within a reasonable period, in accordance with the relevant legislation. Violence and mistreatment, physical or psychological, are totally prohibited and are crimes under Cuban law. All prisons are subject to a system of inspection that is independent of the authority responsible for running them.[277]

Former prisoners and the family members of current prisoners expressed uncertainty about who was responsible for monitoring conditions and investigating complaints inside prisons, and repeatedly said that oversight was neither independent nor effective. Prisoners said they were not informed of their right to complain nor how to register abuses.

The dissidents we spoke with said that complaints of abuse are routinely met with inadequate investigations, indifference, or even reprisals. Alexander Santos Hernández, who was imprisoned in Cuba Sí! prison in Holguín from 2006 to 2008, said of the officer who was supposedly in charge of receiving complaints: “It is as if [the complaint] were never made, because whatever it is, the officers are always right. The internal monitor never disciplines or calls attention to an officer for any violation.”[278] Digzan Saavedra Prat, a political activist who was also imprisoned in Cuba Sí! in 2008 for “dangerousness,” said he went to the internal prison overseer to seek help when a common prisoner threatened him. In response, the official told him it was not his problem.[279]

In three cases, former political prisoners said that the very individuals responsible for monitoring abuses were themselves the perpetrators of beatings and harassment. Former political prisoner Víctor Yunier Fernández Martínez said that the internal overseer in prison 1580 in Havana—where he was imprisoned on a “dangerousness” charge—“was one of the ones who threatened me and even ordered several officers to assault me on September 27, 2006.”[280]

Left with no other remedy for abuses, political prisoners routinely undertake hunger strikes and other drastic measures to call attention to their treatment. However, these actions are often met with further reprisals by prison officials. For example, Yordis García Fournier went on hunger strike for more than a month in 2008 to protest his unjust treatment by prison authorities. As punishment for his not eating, prison officials cut off García’s family visits and placed him in a solitary confinement cell.[281]