On May 3, 2019, the Fourth Circuit became the first federal court of appeals to hold that the indefinite solitary confinement of people on death row is a violation of the Eighth Amendment. The case, Porter v. Clarke, was praised as a step forward for the rights of those held on death row, as well as a major victory in the battle against solitary confinement. Prior to Porter, several courts, including the Supreme Court, had found that prolonged solitary confinement can violate the Due Process Clause of the Fourteenth Amendment. However, none had held that such treatment violated the Eighth Amendment, much less for people incarcerated on death row. This Comment argues that while the reasoning in Porter is legally and scientifically sound, it probably will not be adopted by other circuits. Part I outlines the decision and explains how the facts of the case are similar to conditions on death row in several other circuits. Part II then argues that idiosyncrasies of the litigation in Porter, as well as recent Supreme Court death penalty jurisprudence, make the case untenable for use in other circuits. Finally, Part III contends that, despite the hurdles discussed in Part II, the decision is not totally toothless outside of the Fourth Circuit. Using two case studies of similar litigation, that Part argues that the Porter decision should be used as a tool for encouraging settlement or voluntary changes in death row conditions elsewhere.