litigating against solitary confinement on the basis of the fourteenth amendment and due process is another less common strategy inmates have used. the fourteenth amendment limits the “types of prisoners” that can be placed in solitary confinement and the time the prisoners can be confined. the due process clause within the fourteenth amendment also regulates solitary confinement in that prisoners must be given reviews before and during their placement in solitary confinement. court cases made on these bases do not necessarily address any “underlying problems” of solitary confinement, but they do call for increased monitoring, hearing, and reviews.