Incarcerated Men Ask Court for Heat Protections for Forced Field Work

 Inhumane conditions of forced agricultural labor continue at Angola prison despite prior orders

Today, Voice of the Experienced (VOTE) and seven men who are incarcerated at Louisiana State Penitentiary (Angola) again asked a federal court to grant a preliminary injunction and temporary restraining order to protect the people forced to work on the so-called Farm Line during periods of extreme heat. The Farm Line is a punitive forced work assignment in which men are marched to the fields to perform agricultural manual labor without protective gear, adequate farming equipment, or clean drinking water. The Farm Line is reviled for its brutal conditions, including the psychologically harmful impact experienced by Black men forced to engage in practices akin to nineteenth century slavery.

“As we enter the summer season in Louisiana, the State continues to force incarcerated people to work in the fields of a former plantation, under dangerous conditions, putting them at extreme risk of heat-related illness,” said Samantha Pourciau, Senior Staff Attorney at the Promise of Justice Initiative. “Nearly a full year after the courts ordered the State to change its practices to ensure the health and safety of incarcerated workers, the State’s response to the judge’s orders has decreased protections. The State of Louisiana continues to exploit people under its care without regard to their mental or physical health or safety.”

In July 2024, Judge Brian Jackson of the Middle District of Louisiana 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 his 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 affirmed aspects of the ruling on appeal requiring the State to provide shade and protective equipment to those forced to labor in the fields. With that injunction now expired, and another heat season quickly approaching, PJI and Rights Behind Bars filed this new request in light of the State’s continued deliberate indifference to the health of men on the Farm Line. 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.

“Angola’s purported remedial measures are merely a smokescreen,” said Lydia Wright, Supervising Attorney at Rights Behind Bars. “The State’s galling decision to raise the heat alert threshold by three degrees--a metric with no scientific basis--is resounding evidence of the State’s bad faith. The Farm Line cannot be made safer; instead, it simply must end.”

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. If certified as a class action, the suit will include a subclass of individuals with disabilities, bringing claims under Americans with Disabilities Act and Rehabilitation Act.  

The judge initially set a trial date for November 18, 2024, but has subsequently postponed the start indefinitely. A two-day evidentiary hearing on class certification is scheduled to begin on April 23, 2024.

Learn more:

·       Memo in Support of PI/TRO Filing – March 26, 2025

·       Release on Class Certification Filing – with declarations describing racism and harm

·       Fifth Circuit Ruling and Order - August 15, 2024

·       Middle District Ruling and Order – July 2, 2024

·       Filing: Plaintiffs’ Application for a Preliminary Injunction and Temporary Restraining Order

·       Release: PJI & RBB Challenge Unconstitutional Conditions of Forced Labor at Angola

·       Filing: First Amended Class Action Complaint for Declaratory and Injunctive Relief

·       Release: Incarcerated Men Seek Emergency Order to Stop the Farm Line at Angola

·       Report: Punitive by Design: The Farm Line at Louisiana State Penitentiary

·       Website: End Plantation Prisons: Forced Labor in the Bayou State

Recent/past quotes on this case

"The brutality of the Angola Farm Line isn’t a secret. It is visible to any and everyone who has ever set foot in Angola as an incarcerated person or staff,” said Ronald Marshall, Chief Policy Analyst at VOTE, associational plaintiff in the suit. “Officers on horseback with shotguns monitor as men soaked in their own sweat toil day in and day out in fields without safety gear or fair wages, often suffering near-death injuries and heat exhaustion. I witnessed these stories play out daily, and every day, I prayed for the men to find the strength to endure.” 

“For more than a hundred years, incarcerated men have put their lives at risk in the scorching fields of Louisiana's prisons,” said Samantha Kennedy, Executive Director at the Promise of Justice Initiative. “The Farm Line is unambiguously coercive and exploitative. It’s beyond time for Louisiana to end this degrading and unconstitutional practice.”