(CN) - Officials at California's Corcoran State Prison did not violate a convicted gang member's rights by restricting outdoor exercise for more than a year in the wake of a violent inmate uprising against corrections officers, the 9th Circuit ruled Thursday.
Rival gangs banded together during the January 2002 riot - an "unprecedented" event that one prison official described as the most violent riot he'd seen in 20 years on the job, according to a ruling.
Wielding crudely fashioned weapons, the gangs attacked the Kings County prison's employees in the exercise yard, killing one corrections officer and injuring 21 others.
After quelling the riot, prison officials instituted an extended lockdown and curtailed most inmate activities for several months. Officials returned the prison to normalcy gradually, contingent on the ongoing cooperation of the gangs that had been involved in the riot.
By April 1, 2003, full exercise privileges had been restored for all prisoners, the ruling states.
Stephen Noble IV, a member of one of the gangs involved in the riot, was an inmate in the prison's substance abuse treatment center when the riot broke out. Noble says he did not participate in the violence and that prison's subsequent lockdown violated his civil rights. He sued prison officials D. Adams and D. Cuevas in California District Court, alleging violations of his Eighth Amendment right to outdoor exercise.
Chief U.S. District Judge Anthony Ishii denied the officials' motions for qualified immunity, finding that Adams and Cuevas had failed to show a legitimate purpose for the lockdown past Jan. 30, 2002.
The federal appeals panel in San Francisco reversed the lower court Thursday, saying that its "approach manifestly trespassed against our warnings not to micro-manage prisons."
"If anything, the record demonstrates that the officials were continuously, prudently, and successfully looking out for the safety, security, and welfare of all involved, staff and prisoners alike," Judge Stephen Trott wrote for the three-judge appeals panel (emphasis in original). "This scenario is precisely what the doctrine of qualified immunity is designed to cover."
Trott added that "it was not clearly established in 2002 - nor is it established yet - precisely how, according to the Constitution, or when a prison facility housing problem inmates must return to normal operations, including outside exercise, during and after a state of emergency called in response to a major riot, here one in which inmates attempted to murder staff."
The panel reversed the District Court's ruling and remanded the case with instructions to enter a judgment for the officials.
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