Does a prison officer have authority to restrict outdoor exercise for the purpose of preventing inmates from exercising outdoors?

MultiRegion, United States of America

The following excerpt is from Grizzle v. Cnty. of San Diego, Case No.: 3:17-cv-0813-JLS-PCL (S.D. Cal. 2017):

Prison officials may restrict outdoor exercise on the basis of weather, unusual circumstances, or disciplinary needs. See Spain, 600 F.2d at 199. "The cost or inconvenience of providing adequate [exercise] facilities[, however,] is not a defense to the imposition of a cruel punishment." Id. at 200. Determining what constitutes adequate exercise requires consideration of "the physical characteristics of the cell and jail and the average length of stay of the inmates." Houseley v. Dodson, 41 F.3d 597, 599 (10th Cir. 1994). For example, in Pierce, 526 F.3d 1190, the pretrial detainees in administrative segregation were typically allowed only 90 minutes weekly for exercise. Id. at 1212. The court there found this allotment was clearly grounds for a violation of 1983. Id.

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