"No one truly knows a nation until one has been inside its jails,” Nelson Mandela once wrote. That was also the quote chosen by Judge Brian A. Jackson of the U.S. District Court for the Middle District of Louisiana in his ruling on August 15, 2024, granting partial specific relief under a previously issued temporary restraining order (TRO), which was itself only part of what was sought by a group of eight state prisoners forced to work the “Farm Line” at the notorious Louisiana State Penitentiary, commonly known as Angola.

The prisoners, with the aid of prisoner rights advocacy group Voice of the Experienced, sued state Department of Public Safety & Corrections (DPSC) Secretary Jimmy LeBlanc in May 2024, alleging that their forced labor on the Farm Line in unsafe and inhumane conditions, particularly during Louisiana’s scorching summer months, violates the Eighth Amendment guarantee of freedom from cruel and unusual punishment. Plaintiffs also sought a TRO halting all work on the Farm Line when the heat index exceeds 88 degrees Fahrenheit.

“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 attorney Oren Nimni, Litigation Director for Rights Behind Bars in Washington, DC, who along with attorneys from the Promise of Justice Initiative (PJI) in New Orleans is representing Plaintiffs.

The Farm Line evokes comparisons to antebellum plantations, where enslaved Africans toiled under brutal conditions. In fact, Angola was once just such a plantation, handed over to the state during Reconstruction, its name a reminder of the country where many of those slaves were sold into servitude. The population remains mostly Black, and like many other prisons in the South, it is essentially a modern-­day slave farm, as PLN reported. [See: PLN, June 2024, pg.1.]

TRO Request Partially Granted

In the TRO granted on July 2, 2024, Judge Jackson called the Farm Line a “compulsory, punitive agricultural or farming labor program” consisting of picking crops, cutting grass and other maintenance. It is a disciplinary assignment for prisoners, who are paid only two cents per hour, if paid at all. They are sometimes forced to pick blades of grass, by hand, from the dirt, or perform other pointless tasks such as watering crops with a Styrofoam cup. The labor serves no rehabilitative purpose, and those who refuse it are thrown in segregation.

All this work is performed in the blazing summer sun, with no shade, few breaks and limited access to water. Prisoners are not provided sufficient personal protective equipment (PPE), such as work boots, gloves and jeans. According to medical experts, working under these conditions creates a “substantial risk of serious heat-­related disorders,” including fainting, heat cramps and heat stroke, which can cause death or “permanent disability.”

Prisoners reported suffering severe heat exposure symptoms during summer months; temperatures climbed as high as 122 degrees Fahrenheit, but guards forced them to continue working anyway. Angola had policies in place to address heat exposure and provide PPE, but Judge Jackson determined that the policies were ignored or “failed to meet the minimum standards” set by state Department of Health or OSHA “for safety in agricultural settings.”

Against this backdrop, the judge concluded that injunctive relief was required to preserve and protect Plaintiffs’ health and safety, “especially as the summer heat arrives in full force.” The “wealth of evidence” that prisoners labored without “shade, sunscreen, or required rest breaks,” amounted to a showing that prison officials are deliberately indifferent to the serious risk of harm they face. But he refused to stop all work on the Farm Line during the summer, as Plaintiffs requested.

Instead, DPSC was ordered to “take immediate measures to correct the glaring deficiencies in their heat-­related policies,” including (1) “lack of shade and adequate rest”; (2) “the failure to provide sunscreen and other necessary protective clothing and equipment”; (3) revision and expansion of a Heat Pathology Medications list; (4) ensuring that prisoners suffering from “health conditions that significantly inhibit thermoregulation” receive medical assessment and are “granted heat precaution duty status”; and (5) provided to incarcerated persons laboring on the Farm Line;” (2) correcting problems with equipment policies, “including to those laboring on the Farm Line;” (3) “a revised and expanded;” (4); and” (5) “an additional heat-­related policy to protect those laboring outdoors when heat index values reach or exceed 113 degrees Fahrenheit.” See: Voice of the Experienced v. LeBlanc, 2024 U.S. Dist. LEXIS 118117 (M.D. La.).

TRO Partially Stayed
by Fifth Circuit

After the TRO, PJI attorney Lydia Wright said Plaintiffs were “elated with the district court’s careful findings that in its current form, the Farm Line falls short of basic constitutional standards.” DPSC, unsurprisingly, was less elated; it appealed the ruling, fretting that the TRO “would effectively open the flood gates to cease any and all work in any institution across the South.” Equally unsurprising, just 10 days later the U.S. Court of Appeals for the Fifth Circuit largely granted a motion to stay the district court’s order while the appeal is pending; the Court’s July 12, 2024, order refused to stay only parts (1) and (2) of the injunction. See: Voice of the Experienced v. LeBlanc, USCA (5th Cir.), Case No. 24-­30420.

Back in the district court, Plaintiffs again asked Judge Jackson to enjoin all Farm Line operation, noting that parts (1) and (2) of the TRO had not been meaningfully implemented. In support, they presented photos showing no more shade had been provided than one “pop-­up tent” that could shelter only a handful of prisoners, who were required to rest on “dusty, rock-­strewn ground.” DPSC also was not providing adequate water or personal protective equipment, they argued. Worse, between July 2 and August 5, 2024, as temperatures routinely topped 100 degrees Fahrenheit, more than 50 prisoners sought medical attention for heat-­related conditions.

Despite these atrocious conditions, which DPSC did not dispute, Judge Jackson still refused to enjoin operation of the Farm Line entirely. However, he found that “the shaded area presently provided to those laboring on the Farm Line is grossly insufficient and reflects a callous disregard for human health and safety.” In an order he issued on August 15, 2024, DPSC was ordered immediately to erect additional tents so that prisoners may rest in the shade “without touching or encroaching on the personal space of their fellow inmates.” Tents must be placed close enough to work areas so that prisoners do not have to travel long distances to rest, and they must have access to chairs, clean cups and ice water. Finally, prisoners must be provided a 15-­minute break for every 45 minutes worked during heat alerts. The case remains pending, and PLN will continue to update developments as they are available. See: Voice of the Experienced v. LeBlanc, USDC (M.D. La.), Case No. 3:23-­01304.  

Additional sources: The Appeal, WIAT

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