In support of this assertion, Plaintiff argues that courts across the country have recognized such a claim, citing Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995); Washington-El v. Beard, No. CIV.A. 08-1688, 2011 WL 891250 (W.D. Pa. Mar. 11, 2011), aff'd, 562 F. App'x 61 (3d Cir. 2014); Spencer v. Courtier, No. CA 09-124, 2011 WL 2670198 (W.D. Pa. May 23, 2011), report and recommendation adopted, No. 1:09-CV-124-SJM-SPB, 2011 WL 2669053 (W.D. Pa. July 7, 2011); Ruiz v. Johnson, 37 F. Supp. 2d 855 (S.D. Tex. 1999), rev'd and remanded on other grounds Ruiz v. United States, 243 F.3d 941 (5th Cir. 2001); Jones "El v. Berge, 164 F. Supp. 2d 1096 (W.D. Wis. 2001); Walker v. State, 68 P.3d 872 (Mont. 2003); Braggs v. Dunn, 257 F. Supp. 3d 1171 (M.D. Ala. 2017); and Graves v. Penzone, No. CV-77-00479-PHX-NVW, 2019 WL 201412 (D. Ariz. Jan. 15, 2019). While other district courts have recognized an Eighth Amendment violation for placing seriously mentally ill inmates in solitary confinement or administrative custody prior to the conduct alleged by Plaintiff in this case, the cases cited by Plaintiff to support his position that the right was clearly established falls short of showing a robust consensus of persuasive authority on this issue at the time the conduct occurred.