Federal Court notes the State was deliberately indifferent to substantial risk of harm

Tuesday, a federal judge granted a Temporary Restraining Order (TRO) in VOTE v. LeBlanc requiring state officials to “take immediate measures to correct the glaring deficiencies in their heat-related policies” at the Louisiana State Penitentiary (Angola). In his order, Judge Brian 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 court order gives the state seven days to come up with a plan to improve policies and procedures and protect the incarcerated men forced to work in extreme heat conditions. The ruling also addressed the role of climate change and extreme heat on human health, including that of people who are incarcerated.

“Today’s ruling is validation that the unconstitutional and inhumane conditions of forced labor that exist at Louisiana State Penitentiary will no longer stand unchallenged,” said Lydia Wright, Associate Director of Civil Litigation at the Promise of Justice Initiative. “We are glad that Judge Jackson agreed that the danger for incarcerated people working in extreme heat on the Farm Line is open and obvious. We are encouraged by this ruling and will continue fighting for our clients’ right to not be forced to labor in unsafe and life-threatening conditions.”

In May, Voice of the Experienced (VOTE) and eight men who are incarcerated at Angola requested a preliminary injunction and temporary restraining order to stop prison officials from operating the so-called Farm Line whenever the heat index reaches or exceeds 88 degrees. Following a hearing on June 18, today’s ruling stopped short of granting the request to stop the Farm Line entirely. Rather, Judge Brian Jackson issued a Temporary Restraining Order with a seven-day deadline for the state to submit a memorandum containing their proposed remedies.

"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. Today's ruling marks a crucial step towards safeguarding those men."

Excerpts of First-Person Testimony Cited in the Court Ruling

The Farm Line is a specific agricultural work assignment at Angola that is a punitive, dangerous, and grossly inhumane form of discipline akin to nineteenth-century slavery. On the Farm Line, as during chattel slavery, men, many of whom have medical conditions and disabilities, are forced to work Angola’s fields in oppressive heat without proper protection, modern farming equipment, or even clean drinking water. In the ruling, the judge agreed that “conditions on the Farm Line ‘create a substantial risk of injury or death.’”

“It is hard to overstate how life-threatening the combination of forced labor, high heat, and Angola’s woefully inadequate medical care are for those locked inside,” said Oren Nimni, Litigation Director at Rights Behind Bars. “Today’s court order in the face of these conditions is appropriate and potentially lifesaving. Angola should have ended the Farm Line long ago, and we believe this is a step in that direction.”

Filed in September 2023, plaintiffs’ civil rights lawsuit alleges that the Farm Line, particularly during periods of dangerously high heat, violates the Eighth Amendment rights of all people at Angola to be free from cruel and unusual punishment. The putative class action suit includes a subclass for individuals with disabilities, bringing claims under Americans with Disabilities Act and Rehabilitation Act. A subclass with 13th Amendment claims for individuals convicted by non-unanimous juries was dismissed by the court. The judge has set a trial date for September 30, 2024.

Plaintiffs are represented by PJI, Rights Behind Bars, and Paul, Weiss, Rifkind, Wharton & Garrison LLP.

Learn more:

Incarcerated Men on Angola Prison’s “Farm Line” Win Temporary Relief from Dangerous Labor Conditions

As temperatures soar, judge tells Louisiana to help protect prisoners working in fields

Federal court hears argument to stop farm work at Angola prison in Louisiana in high heat