The Ninth Circuit Court of Appeals issued a memorandum decision on Jan. 29, 2026, in *Cardenas-Ornelas v. Johnson*, a case involving a Nevada state prisoner's constitutional claims against prison officials who allegedly denied him outdoor exercise rights.
Luis Cardenas-Ornelas, a prisoner in the custody of the Nevada Department of Corrections, filed suit under 42 U.S.C. § 1983 against staff at High Desert State Prison. The lawsuit alleged that prison officials violated his Eighth Amendment rights by denying him outdoor exercise and violated his Fourteenth Amendment rights by treating him and his housing unit differently from other prisoners.
Cardenas-Ornelas also brought parallel claims under the Nevada Constitution against the prison officials, seeking relief for what he characterized as unconstitutional conditions of confinement.
The case named nine prison officials as defendants, including Warden Calvin Johnson, Harold Wickham, Charles Daniels, Gary Piccinini, Timothy Struck, Robert Owens, Jessie Brightwell, Manuel Portillo, and Timothy Johnson. Additional defendants J. Alcock and Julio Calderin were also named in the original complaint.
The legal dispute centers on fundamental questions about prisoners' constitutional rights to outdoor recreation and exercise. The Eighth Amendment prohibits cruel and unusual punishment, and federal courts have recognized that completely denying prisoners access to outdoor exercise can violate this constitutional protection under certain circumstances.
The case originated in the U.S. District Court for the District of Nevada, where District Judge Anne R. Traum presided over the proceedings. The district court denied summary judgment on certain claims against Warden Calvin Johnson, prompting the warden to appeal the decision to the Ninth Circuit.
Following oral arguments held Oct. 9, 2025, in Las Vegas, the three-judge panel consisting of Circuit Judges Bennett, Sanchez, and H.A. Thomas issued their memorandum decision. The court noted that it analyzed the district court's denial of qualified immunity in a separate accompanying opinion before addressing Warden Johnson's other arguments on appeal.
One significant issue addressed in the appeal was Warden Johnson's claim that Nevada's Eleventh Amendment immunity provided him with complete protection from the lawsuit. The Eleventh Amendment generally protects states from being sued in federal court by private parties, though this immunity can be waived or may not apply to certain types of civil rights claims against state officials acting in their individual capacities.
The Ninth Circuit confirmed its jurisdiction to review the district court's handling of the Eleventh Amendment immunity question, citing precedent from *P.R. Aqueduct & Sewer Auth. v. Metcalf & Eddy, Inc.*
Section 1983 lawsuits allow prisoners and other individuals to sue state and local officials for violations of their federal constitutional rights. These cases often involve claims about prison conditions, medical care, use of force, and access to courts or religious services.
The memorandum decision carries a notation that it is "not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3." This designation means the ruling resolves the specific dispute between the parties but does not establish binding precedent for future cases in the circuit.
Cases involving prisoners' exercise rights have generated significant litigation across federal courts, as corrections officials must balance security concerns with constitutional requirements. Courts generally recognize that some outdoor exercise is constitutionally required, but the specific amount and type can vary based on security levels and facility constraints.
The Fourteenth Amendment equal protection claims in the case suggest that Cardenas-Ornelas alleged he and prisoners in his unit were treated differently from other inmates without justification. Equal protection violations in prison settings typically require showing that similarly situated prisoners were treated differently without a legitimate penological justification.
Nevada's High Desert State Prison, where the alleged violations occurred, is a medium-security facility that houses thousands of inmates. The prison has faced various lawsuits over the years regarding conditions of confinement and prisoner treatment.
While the full details of the Ninth Circuit's reasoning remain limited in the available excerpts, the case represents another chapter in ongoing litigation over prisoners' constitutional rights in Nevada's correctional system.
The resolution of qualified immunity issues, which the court addressed in a separate opinion, likely determined whether individual defendants could be held personally liable for monetary damages or whether they were protected by the legal doctrine that shields government officials from suit when their conduct does not violate clearly established law.
The case demonstrates the continued importance of federal civil rights litigation in addressing alleged constitutional violations within state prison systems and the complex legal questions that arise when prisoners challenge conditions of their confinement.