The following excerpt is from Grizzle v. Cnty. of San Diego, Case No.: 17-CV-813-JLS (PCL) (S.D. Cal. 2018):
In Spain v. Procunier, 600 F.2d 189, 200 (9th Cir. 1979), the court held that depriving inmates of outdoor recreation violates the Eighth Amendment right against cruel and unusual punishment. The Spain court further stated that "[t]he cost or inconvenience of providing adequate [exercise] facilities is not a defense to the imposition of cruel punishment." Id. In Lopez v. Smith, 203 F.3d 1122, 1133 (9th Cir. 2000), the court found that the prisoner sufficiently stated a constitutional violation when he was denied all outdoor exercise for a period of 45 days.
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