646 F.3d 1138
9th Cir.2011Background
- Noble is an African-American inmate at Corcoran SATF classified as Level IV in Facility C.
- A January 9, 2002 riot by African-American inmates against staff led to a prison-wide lockdown.
- During lockdown Noble was deprived of outdoor exercise and regular privileges for about seven months.
- The lockdown began after the riot and continued pending investigation and security considerations.
- Starting April 2002, authorities began phased restoration of privileges, with full outdoor exercise not restored until April 1, 2003.
- Noble sued under 42 U.S.C. § 1983 for Eighth Amendment outdoor-exercise rights; district court denied summary judgment and qualified immunity; Ninth Circuit reversed and remanded for judgment for defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the defendants were entitled to qualified immunity on Noble’s outdoor-exercise claim. | Noble argues the lockdown violated clearly established rights. | Defendants contend the rights were not clearly established and reasonable penological judgments apply. | Qualified immunity denied for Noble’s claim; court held it was not clearly established in 2002. |
Key Cases Cited
- Norwood v. Vance, 591 F.3d 1062 (9th Cir. 2010) (deference to prison officials in emergencies; broad leeway in restoring normal operations)
- Hayward v. Procunier, 629 F.2d 599 (9th Cir. 1980) (emergency lockdowns may justify restrictions with reasonable leeway to officials)
- Hoptowit v. Ray, 682 F.2d 1237 (9th Cir. 1982) (temporary suspension of some services during genuine emergencies; deference to officials)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified-immunity framework (reaffirmed for analysis))