Is a prison's policy of not providing outdoor exercise for inmates assigned to administrative segregation a violation of the Eighth Amendment?

In Spain, this court held that a prison's policy of not affording outdoor recreation violated the Eighth Amendment. 600 F.2d at 199 (upholding district court's order that prison officials provide at least one hour of outside recreation per day, five days a week). Although the court in Spain declined to decide whether deprivation of outdoor exercise was a "per se violation" of the Constitution, the court recognized that "some form of regular outdoor exercise is extremely important to the psychological and physical well being of the inmates." Id. at 199. The court emphasized that the plaintiffs were in long-term incarceration where they were in continuous segregation, generally spending twenty-four hours each day in their cells alone. Id. Under these conditions, deprival of outdoor exercise constituted cruel and unusual punishment. Id.; see also Toussaint v. Yockey, 722 F.2d 1490, 1493 (9th Cir.1984) ("substantial constitutional question" raised when prison officials failed to provide sufficient exercise to inmates assigned to administrative segregation for over one year).