Does a temporary denial of outdoor exercise violate the Eighth Amendment?

In Hayward v. Procunier, 629 F.2d 599, 603 (9th Cir.1980), cert. denied, 451 U.S. 937 (1981), involving a temporary denial of outdoor exercise, this court did not find an Eighth Amendment violation. Hayward involved prisoners who were denied exercise for 30 days during an emergency lockdown. This court found that a lockdown was an unusual circumstance justifying the temporary denial of outdoor exercise. As we explained, "the measure was temporary and plaintiffs here were allowed approximately the minimum exercise mandated in Spain within one month after the imposition of the lockdown." Hayward v. Procunier, 629 F.2d at 603.