Judge says he can't force Louisiana to fix Angola prison farm labor conditions

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U.S. District Judge Brian Jackson in Baton Rouge addressed a long-running lawsuit filed by prisoners who work in the fields surrounding the Louisiana State Penitentiary at Angola. The plaintiffs said they labor outdoors in extreme heat and face dangerously harsh conditions on what is known inside the facility as the “farm line.”

Jackson released a 60-page opinion on Tuesday concluding he could not order the state to correct the conditions. He said his decision would have been different just a few months ago, but a ruling by the 5th U.S. Circuit Court of Appeals in March altered the legal landscape.

In that separate case, Parker v. Hooper, prisoners accused Angola officials of providing unconstitutionally poor medical care. The New Orleans-based appellate court ruled with the state in March. Jackson wrote that the 5th Circuit’s decision in that case weakened the standard for proving cruel and unusual punishment under the Eighth Amendment.

Under the new threshold, Jackson wrote, Louisiana is cleared of liability if it can demonstrate that it took any action toward remedying a potential Eighth Amendment violation, no matter how ineffective that action may be. The standard no longer requires the state’s response to meet a substantive adequacy test, only that some response was attempted.

The Angola facility, formally the Louisiana State Penitentiary, sits on land that operated as a working plantation before the Civil War and historically relied on convict labor. Prisoners assigned to field work have long been under scrutiny for exposure to extreme summer temperatures, physically demanding assignments, and limited access to medical evaluation.

The 5th Circuit Court of Appeals is widely regarded as one of the most conservative federal appellate courts in the United States. Its March ruling in Parker v. Hooper has now been cited in a second federal case involving conditions at the same facility, limiting the remedial authority of the district court overseeing the prison’s civil-rights litigation.

Jackson’s opinion does not address whether the farm-line conditions violate the Constitution; it concludes only that, under the 5th Circuit’s revised Eighth Amendment standard, the federal court lacks the legal authority to compel the state to implement corrections.