Although prisoners face dangerously harsh conditions while working the “farm line” at the Louisiana State Penitentiary at Angola — including laboring outdoors in extreme heat — a federal judge presiding over a long-running suit filed by prisoners forced to work in the fields around Angola has ruled he could not force the state to fix the problem.
In a 60-page opinion released Tuesday, U.S. District Judge Brian Jackson in Baton Rouge said his decision would have been different just a few months ago, but a recent appeals court decision in a separate civil rights case against Angola stayed his hand. In March, the conservative 5th U.S. Circuit Court of Appeals in New Orleans ruled with the state in the other suit — Parker v. Hooper — in which prisoners accused Angola officials of providing unconstitutionally poor medical care. In his Tuesday opinion, Jackson wrote that the 5th Circuit judges’ decision in that case weakened the standard for proving cruel and unusual punishment under the Eighth Amendment. Now, if the state can demonstrate that it took any action toward remedying a potential Eighth Amendment violation — no matter how ineffective — it is cleared of liability.
Jackson reluctantly found that the Louisiana Department of Public Safety and Corrections met that bar in the farm line case.
“Before Parker, the Court would have found Defendants liable under the Eighth Amendment for acting with deliberate indifference to the health and safety of incarcerated persons” working the farm line, Jackson wrote. “Under the Parker ruling, however, the Court is constrained to find that Defendants’ implementation of remedial measures negates a finding of subjective deliberate indifference, even though these remedial measures are inadequate to cure the constitutional violation.”
Four Angola inmates and the New Orleans-based Voice of the Experienced (VOTE), a group that advocates for the rights of the currently and formerly incarcerated, filed a lawsuit in 2023 asking the court to cease farm line work at Angola. Since then, the number of plaintiffs on the suit has grown.
The New Orleans-based legal advocacy organization the Promise of Justice Initiative (PJI) and the national civil rights group, Rights Behind Bars, represented VOTE and the people at Angola in the suit. They argued that the farm line work, especially in excessive heat, violated their clients’ Eighth Amendment protections against cruel and unusual punishment and that it violates parts of the Americans with Disabilities Act and the Rehabilitation Act. On Wednesday, PJI held a press conference to address the ruling.
Samantha Kennedy, executive director for PJI, called the decision “a victory without a remedy.”
Kennedy said she feels vindicated that the court agreed that forcing people to work in dangerously hot conditions is unconstitutional, but described the lack of consequences for Angola and the Department of Corrections as insufficient.
Samantha Pourciau, senior attorney with PJI and lead counsel in the case, said that the litigation accomplished a lot for the people detained at Angola. Those gains, she said, include more frequent breaks, access to water and shade and expanded protections for people with heat-sensitive medical conditions.
But, she said, because the judge did not issue permanent relief for farm line workers, the gains made for inmates could face future setbacks.
“Incremental change, when it is the difference between heat stroke and survival, is real. We do not diminish it, but permanent protection has not been won. This ruling means that every hard-fought improvement can be reversed tomorrow,” Pourciau said.
Louisiana’s Department of Corrections said that the department is pleased with the ruling, adding that the safety of incarcerated individuals remains its top priority including in outdoor work assignments.
“The Department’s heat pathology policies in place include substantial risk-mitigation measures designed to protect inmates working outdoors, including required rest breaks and access to shade, fans, water, and other safeguards,” said Falon Brown, the department’s press secretary.
When a person arrives at Angola, they’re assigned a job, including working the “farm line,” which entails picking crops from a field under the watch of armed guards. Farm line workers earn little pay — after three years working without pay, they’re eligible to receive 2 to 4 cents per hour. The prison also uses the farm line as a form of punishment, and people who have worked on it describe it as dehumanizing work reminiscent of slavery — meant to break a person.
While this case — VOTE v. LeBlanc — was in court, Parker v. Hooper was making its way through the federal courts. In that case, the plaintiffs alleged that inadequate medical care at Angola caused prisoners to suffer serious harm, including the “exacerbation of existing conditions, permanent disability, disfigurement, and even death.” U. S. District Judge Shelly Dick of Baton Rouge agreed, finding in November 2023 that medical treatment offered to prisoners “is not care at all,” but instead “abhorrent cruel and unusual punishment.” Dick ordered the prison to be placed under federal oversight. But the state appealed. In March of this year, the 5th Circuit ruled that Dick’s remedy was illegal overreach under the Prison Litigation Reform Act. The judges also found that because the state had made some new reforms to its medical system, it could not be found to be deliberately indifferent to the problem, an essential element for a court to find an ongoing Eighth Amendment violation.
The latter finding proved to be the key for plaintiffs in the farm line case this week.
As was the case with medical care, the Department of Corrections has made some changes to the farm line since the suit was first filed. Those include, according to the judge’s ruling, that Angola has revised its heat policy, added on-site weather monitoring systems, erected shade pavilions and expanded access to water and breaks. Many of those changes, Jackson said, have already brought about some protections for people working on the farm line.
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