The Louisiana State Penitentiary at Angola must consider the “human health and safety” needs of incarcerated people who toil for pennies an hour in the prison’s fields, a federal judge ruled on Tuesday. 

On behalf of incarcerated people who work Angola’s “Farm Line,” lawyers filed an emergency motion in May asking for work to halt any time the heat index rises above 88 degrees.

During a hearing last month, U.S. District Judge Brian Jackson heard from lawyers for the Louisiana Department of Corrections and from opposing lawyer Lydia Wright, associate director of civil litigation at the Promise of Justice Initiative (PJI), which in this case represents imprisoned people forced to do agricultural work and the organization Voice of the Experienced (VOTE).

On Tuesday, in his ruling Jackson allowed the Farm Line to continue — just as other agricultural work in Louisiana continues during the hot weather, he wrote. 

To continue, however, the Farm Line must undergo marked changes, Jackson wrote, as he issued a temporary restraining order, ordering prison officials to “take immediate measures to correct the glaring deficiencies in their heat-related policies.”

The DOC must submit a memo to the court outlining its proposed remedies within seven days of Tuesday’s order, Jackson ruled.

Update: On Friday, July 5th, after DOC filed notice of their intent to appeal, a panel of judges on the U.S. 5th Circuit Court of Appeals issued a temporary administrative stay of Judge Jackson’s order. The stay will be in place until July 19, as the court determines whether or not a more lengthy stay will be instituted as the appeal plays out. Still, observers believe Jackson’s ruling is significant.

“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,” Wright said in a statement.

Climate change makes the Farm Line policy corrections even more crucial, Jackson wrote, describing how the Farm Line operates under increasingly scorching conditions. The prison’s own temperature logs from May to October 2023 showed 145 days when heat alerts were issued, or should have been, he noted.

Department of Corrections lawyers had argued that stopping Farm Line work in high heat would deprive thousands of prisoners at Angola of fresh vegetables harvested from the fields and used in prison kitchens. Also, Angola work crews had access to reasonable breaks and even sipped on Gatorade, they contended.

Jackson found otherwise, as he rendered his decision. “The wealth of evidence here shows that incarcerated persons laboring on the Farm Line are not provided with shade, sunscreen, or required rest breaks. Further, the declarations from named Plaintiffs uniformly provide that breaks are seldomly given, that the water provided is dirty, that they are required to work beyond their physical capacities, and that they are not provided with other necessary protective equipment, like lace-up boots or sunhats.” 

Without relief, Jackson wrote, “It is apparent that the immediate threat of irreparable harm amounts to death and permanent injury for incarcerated persons laboring on the Farm Line.” 


The Louisiana State Penitentiary at Angola. Credit: U.S. Justice Action Network

Watering plants with a five-gallon bucket and a Styrofoam cup

Evidence also showed that the DOC’s lack of attention to the field workers’ needs stemmed from “deliberate indifference” to such risks, Jackson found, which likely violates the men’s constitutional rights, specifically the Eighth Amendment’s ban on cruel and unusual punishment.

Also, from a review of the emergency sick-call medical records from April and May this year, Jackson found “multiple inmates with serious illnesses or pre-existing conditions were laboring in the field under no work restrictions. One of these men suffered from acquired immunodeficiency syndrome (AIDS), and another was a fifty-three-year-old man with a history of pre-diabetes, fainting, knee pain, asthma, and osteoarthritis.”

One of the case’s named plaintiffs, Myron Smith, who is more than 50 years old and in poor health, described the primitive tasks he’d been assigned. “[E]arlier this year, officials gave me a five-gallon bucket and a Styrofoam cup and forced me to hand-water rows of watermelons,” he’d said. “This was physically painful and difficult work, particularly given the extreme heat and humidity in the fields. I have also been forced to hand-pick grass. I could not refuse to do this work without risking disciplinary action and serious harm.”     

The request to halt the Farm Line during extreme heat is part of a broader class-action lawsuit brought by prisoners seeking to end the forced agricultural labor at Angola altogether. The lawsuit was brought by incarcerated members of VOTE.

The practice of prison labor is allowed under the 13th Amendment of 1865, which abolished slavery throughout the United States. “Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States.” Those words – “except as punishment for a crime” – created an exception for prisons, allowing the use of prisoners as free and forced labor.

The VOTE lawsuit argues that the Farm Line serves “no legitimate penological or institutional purpose” and violates the prisoners’ Eighth Amendment right against cruel and unusual punishment.

Jackson gave a glancing nod to that contention in Tuesday’s decision. Some of Angola agricultural programs resembled “modern-day farming operations,” he wrote, while “others, such as the Farm Line, serv(ed) an almost purely penological function.”

“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, VOTE’s chief policy analyst. 

Marshall outlined what he saw every day when imprisoned at Angola. “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,” he said. “Today’s ruling marks a crucial step towards safeguarding those men.”

In the plan due to Jackson by next week, prison officials must correct “the lack of shade and adequate rest” for those laboring on the Farm Line; outline the provision of sunscreen and other necessary protective supplies and clothing; submit a revised “Heat Pathology Medications” list; create a procedure to protect field workers who suffer from certain health conditions; and adopt heat-related policies for field workers when the heat index reaches or exceeds 113 F., the temperature at which the National Weather Service issues excessive heat warnings.