main traditional disciplinary tools' of our prison systems.  President's Commission on Law Enforcement and Administration of Justice, Task Force Report: Corrections 50-51 (1967); S. Rubin, et al., The Law of Criminal Corrections 293 (1963).18  Plaintiff has directed our attention to currently operative rules in other jurisdictions which limit the duration of segregated confinement, and to several commentaries recommending or approving such rules.19  In several states, however, incarceration in segregated cells seems to be for an indefinite period, as it is in New York.20  The federal practice appears to be that prisoners shall be retained in solitary 'for as long as necessary to achieve the purposes intended,' sometimes 'indefinitely.'  Furthermore, 'willful refusal to obey an order or demonstrated defiance of personnel acting in lineto note that the full vindictive flavor of defendants' treatment of Sostre is indicated by one incident, relegated to a footnote in the majority opinion.  The day after Judge Motley ordered Sostre's release from over a year of segregation, he was again disciplined for having 'dust on his cell bars.'  This caused him to miss the regular July 4th celebration, which would have brought him in contact with prisoners from another part of the prison, such contact being permitted only once a year on July 4.  Judge Motley found that the punishment was imposed upon Sostre in retaliation for his legal success before her.


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The district judge found that the isolation imposed on Sostre was 'dangerous to the maintenance of sanity' and "could only serve to