Incarcerated Men Again Win Heat Protections for Forced Field Work
Judge recognizes inhumane conditions of forced agricultural labor that continue at Angola prison
Today, a federal judge granted a Second Temporary Restraining Order (TRO) against the Louisiana Department of Corrections and Public Safety related to the operation of the “Farm Line” at Louisiana State Penitentiary (Angola) during periods of extreme heat. In his order, Judge Brian Jackson requires the State to monitor temperature and humidity every 30 minutes and to issue a “Heat Alert” when the temperature meets or exceeds 88 degrees.
“This ruling affirms a basic truth: the men we represent are human beings who deserve dignity, safety, and protection from extreme heat,” said Samantha Pourciau, Senior Staff Attorney at the Promise of Justice Initiative. “This second temporary restraining order is a necessary next step to protect the constitutional rights and basic human dignity of our clients. We will continue to fight vigorously to ensure that no one is subjected to unlawful, inhumane, and unsafe treatment.”
On March 26, 2025, Voice of the Experienced (VOTE) and seven men who are incarcerated at Louisiana State Penitentiary (Angola) asked Judge Jackson of the Middle District of Louisiana to grant a second preliminary injunction and temporary restraining order to protect the people forced to work on the Farm Line during periods of extreme heat. At the time this lawsuit was filed in 2023, Angola’s policy was to issue a heat alert when the heat index reached 88 degrees. For this upcoming summer, the State inexplicably changed their policy to increase that threshold to 91 degrees, exacerbating the danger of working outside for people forced to work the Farm Line.
As the Court itself noted in today’s ruling:
“Incredibly, although the Court found that Defendants’ proposed remedies to address the threat to human health and safety on the Farm Line ‘border[ed] on bad faith,’ Defendants nonetheless chose to raise the Heat Alert threshold in effect as of the Court’s July 2 [, 2024] Order.” page 16 of the Ruling and Order.
“For a second consecutive year, the court has unequivocally condemned Angola prison for perpetuating an archaic system of physical punishment that contradicts scientific understanding and basic legal principles,” said Lydia Wright, Supervising Attorney at Rights Behind Bars. “There is no justifiable reason for Angola to continue operating the Farm Line.”
With another heat season quickly approaching and last summer’s injunction now expired, PJI and Rights Behind Bars filed these emergency requests considering the State’s continued deliberate indifference to the health of men on the Farm Line. This ruling involves the TRO only and, by law, is effective for 10 days from today. The court indicated that there would be a separate ruling on the preliminary injunction.
“I’ve worked the Farm Line — it’s torture,” said Anthony Hingle with VOTE, associational plaintiff in the suit. “You’re already locked up, but the State still finds a way to enslave you — it’s punishment on top of punishment. They steal your labor, push your body to the edge in deadly heat, and work you ‘til your body is beat down and you can’t work anymore. We’re grateful the Court sees this for the emergency it is. And we’re proud of our brothers inside — standing up, speaking out, and demanding their basic human rights.”
In July 2024, Judge Jackson partially granted our first motion for a preliminary injunction and ordered prison officials to “take immediate measures to correct the glaring deficiencies in their heat-related policies.” In that order, Judge Jackson said that “[i]njunctive relief is required to preserve and protect human health and safety, especially as the summer heat arrives in full force.” The judge also noted ongoing risks caused by the State’s operation of the Farm Line, including “haphazard” and “grossly insufficient” shade and water, the high number of heat-related sick calls, and Angola officials’ insufficient medical response to heat-related emergencies – all of which the judge said reflected “a callous disregard for human health and safety.” The Fifth Circuit quickly permitted aspects of the ruling on appeal to be implemented, requiring the State to provide shade and protective equipment to those forced to labor in the fields.
Background:
The “Farm Line” is a forced-labor assignment in which men are sent to fields to perform agricultural manual labor without sufficient protective gear, equipment, or clean drinking water. The Farm Line is reviled for its brutal conditions, including the psychologically harmful impact experienced by men forced to engage in practices akin to nineteenth century slavery. The Promise of Justice Initiative filed this lawsuit in September 2023. Prison administrators have made insufficient attempts to improve conditions.
Filed in September 2023, VOTE v. LeBlanc (Civil Action No.: 3:23-cv-1304-BAJ-EWD) seeks an end to the Farm Line, alleging that the Farm Line violates the Eighth Amendment rights of all people to be free from cruel and unusual punishment, particularly during periods of dangerously high heat. In September 2024, we filed a motion for class certification which highlighted the harms and explicit racism experienced by the plaintiffs and others who are forced to work the Farm Line. The judge initially set a trial date for November 18, 2024, but has subsequently postponed the start indefinitely.