In 1890, the U.S. Supreme Court was just three decades removed from ruling that blacks had “no rights which the white man was bound to respect” and six years away from declaring racial segregation constitutional. Yet, even in an era of such moral and legal confusion, the court was discerning enough to label the state’s use of solitary confinement an “infamous punishment” and very nearly declare it unconstitutional.

In re Medley, though, the court stopped short of ruling that solitary confinement constitutes a violation of the Constitution’s prohibition against cruel and unusual punishment. The use of solitary confinement has skyrocketed since then, especially over the last three decades, and with it so has evidence of its devastating effects on prisoners’ physical and mental health.