Norwood

Facts

Gregory Norwood was incarcerated at CSP-Sacramento, a maximum security prison, during a particularly violent period in the prison’s history. Norwood brought this section 1983 action alleging that prison officials violated the Eighth Amendment when they denied him outdoor exercise during four separate extended lockdowns over the course of two years.

The prison initiated these lockdowns after serious inmate assaults on staff. During the lockdowns, inmates were con- fined to their cells and normal programs were suspended while officials investigated the violence. Based on what they learned, officials gradually eased restrictions on specific gangs, ethnic and racial groups, restoring outdoor exercise sooner for inmates who they believed would pose less risk of further violence. Norwood was not a gang member, but gang members often pressured unaffiliated inmates of the same race or ethnicity to assist them. Prison officials therefore believed that limiting the scope of lockdowns to gang mem- bers would be inadequate to ensure safety. NORWOOD v. VANCE 437 During this two-year period, there were also numerous inmate-on-inmate attacks. Officials did not…