Noble v. Adams, 646 F.3d 1138

Adams and Cuevas were SATF prison officials who ordered a lockdown of Corcoran State Prison after a violent January 9, 2002 riot on Facility C’s yard.
Noble, an African-American Level IV inmate and former Crip, sued under 42 U.S.C. § 1983 alleging Eighth Amendment outdoor exercise rights were denied during the lockdown.
The lockdown curtailed outdoor exercise and regular privileges from January 9, 2002, through early 2003, with a phased and gradual resumption of activities beginning April 2002 and concluding by April 1, 2003.
The facility conducted an extended investigation and implemented a status-report system (Program Status Reports) to monitor safety and plan a return to normal programming.
The district court granted summary judgment against Noble on some grounds and denied qualified immunity; on appeal, the circuit reversed, finding qualified immunity shielded the officials, and remanded for entry of judgment in favor of the defendants.
The court relied on Norwood and related doctrine to defer to prison officials’ judgment in emergency lockdowns while assessing penological purposes and risks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the right to outdoor exercise during lockdowns was clearly established in 2002.	Noble argues a clearly established right existed.	Officials contend no clearly established standard applied to length and management of lockdowns.	Not clearly established; qualified immunity applies.
Whether the lockdown violated the Eighth Amendment given penological purposes and risks.	Noble contends the deprivation was deliberate indifference.	Officials assert a legitimate penological purpose and reasonable restraint during emergency.	Lockdown justified; officials entitled to qualified immunity.
Whether the district court erred by focusing on post-January 30, 2002 evidence to deny immunity.	Noble argues ongoing indifference beyond 30 January 2002.	Record supported ongoing assessment under emergency conditions.	District court erred; deference to officials' judgment maintained.
Whether Hayward, Hoptowit, and Norwood support a different outcome for this case.	Noble relies on Hayward/Hoptowit for stricter limits.	Norwood allows wide deference during emergencies.	Norwood framework controls; immunity remains.

Norwood v. Vance, 591 F.3d 1062 (9th Cir. 2010) (deference to prison officials’ judgment in emergencies; lockdowns permitted with risk assessment)
Hayward v. Procunier, 629 F.2d 599 (9th Cir. 1980) (emergency conditions permit restrictions; courts give leeway to administrators)
Hoptowit v. Ray, 682 F.2d 1237 (9th Cir. 1982) (emergency needs may justify temporary service suspensions; defer to officials)
Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity test; not clearly established here)
Pearson v. Callahan, 555 U.S. 223 (2009) (modifies Saucier; courts may apply the two-step analysis with flexibility)
Bell v. Wolfish, 441 U.S. 520 (1979) (recognizes deference to prison officials in balancing safety and inmate rights)
Palmigiano v. Garrahy, 443 F.Supp. 956 (D.R.I. 1977) (early authority on prison conditions and rights)
Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (Eighth Amendment proof framework for inmate rights)