Solitary confinement is typically imposed when inmates’ behavior or other factors-such as threats made against the inmate-create security risks. In 2016-after Lowe’s release-prison officials agreed to provide outdoor exercise to inmates in solitary confinement to settle a different lawsuit. After his release, Lowe filed a lawsuit alleging that his deprivation of outdoor exercise violated the Eighth Amendment’s prohibition of cruel and unusual punishment.įrom 1993 to 2016, CSP barred prisoners in solitary confinement from outdoor recreation. He was not given any access to the outdoors. During those five hours, he was in a room with two narrow, grated windows and no furnishings apart from a chin-up bar. While in solitary confinement at CSP, Lowe was alone in his cell for all but five hours a week. Donnie Lowe spent 11 years in solitary confinement, including a stretch of two years at the Colorado State Penitentiary (CSP).