What is the current state of the law in relation to prison lockdowns?

Neither party addresses the following apparent issue: whether, absent exigent circumstances, when prison officials choose to fulfil their constitutional duty to protect inmates in a matter which compromises their constitutional duty to ensure adequate exercise, have prison officials violated the inmates' Eighth Amendment right to exercise. See Johnson v. Lewis, 217 F.3d 726, 733-734 (recognizing a higher culpable standard to find a constitutional violation when exigent circumstances necessitate "split-second, life-and-death decisions"). Due to prison overcrowding, frequent and severe prison violence has become more common than extraordinary, and the use of lockdowns to

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