Indeed, courts have held that the right to outdoor exercise is a virtual necessity when inmates are kept in continuous segregation (e.g., Spain v. Inmates’ right to engage in outdoor exercise is clearly established under the law, and this right applies even when inmates are housed in solitary confinement.
These effects include appetite and sleep disturbances, anxiety, aggression, paranoia, hallucinations, self-mutilation, panic, withdrawal, cognitive dysfunction, lethargy, depression and suicidal ideation (Haney, 2003).
Research on the effects of solitary confinement indicates that negative emotional, cognitive, social and even physical effects can arise within mere days (e.g., Appelbaum, 2015 Haney, 2003).
But courts have long recognized that solitary confinement raises serious mental and physical health concerns (e.g., In re Medley, 1890 Davis v. Solitary confinement is typically imposed when inmates’ behavior or other factors-such as threats made against the inmate-create security risks. In 2016-after Lowe’s release-prison officials agreed to provide outdoor exercise to inmates in solitary confinement to settle a different lawsuit. After his release, Lowe filed a lawsuit alleging that his deprivation of outdoor exercise violated the Eighth Amendment’s prohibition of cruel and unusual punishment.įrom 1993 to 2016, CSP barred prisoners in solitary confinement from outdoor recreation. He was not given any access to the outdoors. During those five hours, he was in a room with two narrow, grated windows and no furnishings apart from a chin-up bar. While in solitary confinement at CSP, Lowe was alone in his cell for all but five hours a week. Donnie Lowe spent 11 years in solitary confinement, including a stretch of two years at the Colorado State Penitentiary (CSP).
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