The federal district court for the Middle District of Louisiana granted in part an application by incarcerated persons who labor on the “Farm Line” at the Angola penitentiary in Louisiana for a preliminary injunction or temporary restraining order enjoining agricultural labor on the Farm Line when heat index values exceed 88°F. The court found that the evidence at this stage showed that Angola’s heat-related policies were inadequate to mitigate risks of heat-related disorders, resulting in a substantial risk of serious harm. The court said the “worsening climate situation” in Louisiana and Angola compounded the inadequacies of the policies. The court further found that plaintiffs had shown a substantial likelihood of establishing that the defendants had been deliberately indifferent to these risks in violation of the Eighth Amendment. The court also found that the plaintiffs showed an immediate risk of irreparable injury and that the balance of interests favored an injunction. Citing the Prison Litigation Reform Act (PLRA) provision limiting relief in prison conditions lawsuits to remedies that reduce risk to “a socially acceptable level,” the court did not entirely enjoin operation of the Farm Line when the 88°F threshold was reached but instead ordered the defendants to “take immediate measures to correct the glaring deficiencies in their heat-related policies.” The court listed five sets of actions that the defendants were required take and required them to submit a memorandum regarding proposed remedies.

Class action alleging that agricultural labor conditions at the Louisiana State Penitentiary in Tunica, Louisiana violated incarcerated persons' constitutional rights.

Voice of the Experienced v. LeBlanc

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Louisiana Federal Court Found that Incarcerated Persons Were Entitled to Preliminary Injunctive Relief in Eighth Amendment Challenge to Heat Conditions on Angola Farm Line

Filed

United States of America

Louisiana

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Louisiana Federal Court Found that Incarcerated Persons Were Entitled to Preliminary Injunctive Relief in Eighth Amendment Challenge to Heat Conditions on Angola Farm Line

Policy instrument

Risk

Impacted group

Just transition

Economic sector

Finance