Louisiana State Penitentiary in Angola
A federal judge has ordered Louisiana’s Angola prison to take additional safety measures to protect inmates on the “Farm Line” from extreme heat, concluding that defendant corrections officials have been “deliberately indifferent” to the risks facing agricultural labor.
Judge Brian A. Jackson of the Middle District of Louisiana handed down the order on May 23 in the case of Voice of the Experienced (VOTE) v. James LeBlanc et al. In the complaint, the plaintiffs, including Louisiana State Penitentiary inmates subject to summer Farm Line work, argue that forcing inmates to perform the manual labor puts them at increased risk of physical and psychological harm.
Jackson’s order granted a temporary restraining order to the plaintiffs that requires LeBlanc, secretary of the Louisiana Department of Public Safety & Corrections, and prison personnel to issue a heat alert on the Farm Line when the heat index exceeds 88 degrees Fahrenheit. In addition, defendants must monitor the heat index every 30 minutes, according to the order.
The judge’s order also points out that prison officials revised a health care policy in October of last year that raises the heat alert threshold to 91 degrees. This followed the court’s issuing of its first temporary restraining order in July that put in place precautions such as rest breaks, sunscreen and shade to prevent exhaustion during heat alerts, which were then designated as exceeding 88 degrees.
“The court finds that defendants have likely been deliberately indifferent to (heat) risks by raising the heat alert threshold without sufficient thermoregulatory basis after the court ordered defendants to make changes on the Farm Line to protect human health and safety,” Jackson said in the opinion.
The Promise of Justice Initiative (PJI), which is representing the plaintiffs, said the opinion recognizes the inmates’ humanity and the need to offer protections from extreme heat.
“This second temporary restraining order is a necessary next step to protect the constitutional rights and basic human dignity of our clients,” Samantha Pourciau, the PJI’s senior staff attorney, said in a statement emailed to the Louisiana Record. “We will continue to fight vigorously to ensure that no one is subjected to unlawful, inhumane and unsafe treatment.”
The state’s decision to change the heat alert threshold for the coming summer season was inexplicable, according to the PJI.
In his July 2024 decision, Jackson listed a number of deficiencies related to heat policies on the Farm Line. These included “haphazard” and insufficient shade and water, elevated heat-related sick calls and subpar medical responses.
The PJI has equated the Farm Line to practices similar to 19th-century slavery. The Farm Line forces inmates to engage in manual agricultural labor without adequate gear, equipment or clean drinking water, according to the PJI.
The lawsuit argues that the Farm Line should be disbanded because it violates the Eighth Amendment rights of inmates not to be subject to cruel and unusual punishment.
“... The court finds that (the) plaintiffs have shown a substantial likelihood of success on the merits of their Eighth Amendment claims regarding the heat alert threshold and heat index monitoring,” Jackson said in his most recent opinion.
