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Litigation Heats Up Over Extreme Temperatures in Prisons, Jails

by Matt Clarke and Christopher Zoukis

During a heat wave in the summer of 2017, dozens of protesters gathered outside the Medium Security Institution in St. Louis, Missouri and chanted “shut it down,” after a video showing prisoners at the jail begging for relief from soaring temperatures went viral. But in Texas and elsewhere, prisoners have taken their complaints of extreme – and sometimes deadly – heat to court.

Under a 1977 Texas statute, county jails must keep interior temperatures between 65 and 85 degrees. But over 70 percent of Texas’ 141,000 state prisoners are held in facilities that lack air conditioning, and Texas Department of Criminal Justice (TDCJ) spokesman Jason Clark said prison officials would not consider retrofitting those facilities with climate control, as that would be “extremely expensive.” Of the state’s 105 prisons, only 30 are fully air-conditioned.

The TDCJ pointed to a study indicating the cost of retrofitting just four prisons with AC would run about $350 million – an amount that exceeded the construction costs for four of the state’s 2,500-bed maximum-security facilities. Yet the TDCJ has managed to air condition administrative areas in its older prisons to ensure the comfort of staff members.

At the 100-year-old Ramsey Unit, situated 20 miles south of Houston, administrative areas – including the warden’s office, medical department, and guard dining room and barber shop – have air conditioning. Areas without climate control include places where prisoners live, eat, bathe, exercise and work (unless they work in an administrative area).

The areas that have been converted to have AC typically use small window air conditioning units mounted outside the building which cool a single room; this eliminates the expense of installing ductwork, and allows the AC to be turned off in unused areas.

“[Air conditioning] is seen as a luxury and prison officials don’t want to be seen as running luxurious prisons,” stated David Fathi, director of the ACLU’s National Prison Project.

That mentality can lead to what Fathi called “irrational behavior,” pointing to Louisiana as one example. A federal judge capped the maximum heat index on Louisiana’s death row unit at 88 degrees, and the state spent over $1 million fighting the lawsuit – more than four times the estimated $225,000 cost of air conditioning the unit. [See: PLN, Aug. 2014, p.36].

Texas prison officials said they take precautionary measures when temperatures soar, such as placing fans in common areas and providing ice, cool water and extra showers. But prisoners have reported limited and sporadic availability of water, no extra showers, ice that melts and is not replaced, and fans that are set up to cool guards, not prisoner living areas.

One Ramsey Unit prisoner pointed to a hallway outside the commissary as an example, where fans line the area where guards are posted. Yet where there are only prisoners, no fans are present and the windows can not be opened.

According to Benny Hernandez, incarcerated at the TDCJ’s Price Daniel Unit west of Dallas, 84 prisoners shared a single, 10-gallon water cooler that was locked in a common area. He reported that he and his fellow prisoners received a maximum of one eight-ounce cup of water every four hours – half the amount recommended by the National Academy of Medicine for adults under normal conditions. More hydration is recommended in hot weather. Hernandez said the prison housing areas can reach 140 degrees during summer months.

“It routinely feels as if one’s sitting in a convection oven being slowly cooked alive,” he was quoted in an April 24, 2016 article published by The Intercept.

Although there are no statutory requirements for temperatures in the federal prison system, the Bureau of Prisons’ Facilities Operations Manual sets target temperatures of 76 degrees during the summer and 68 degrees in winter. It also notes that, due to the age of some facilities, the temperature may be a few degrees higher or lower. Just seven of the 122 prisons in the federal system lack air conditioning. The BOP’s temperature control policy does not apply to state prisons or local jails.

Heat-related Deaths and Litigation

The TDCJ has reported 23 prisoner deaths due to heat-related causes since 1998 – though the difficulty of pinning a heat-related cause to a death means the actual number is likely higher. A 2014 report by the University of Texas School of Law’s Human Rights Clinic documented at least 14 heat-related prisoner deaths in TDCJ facilities since 2007 alone.

“They refuse to acknowledge that there is a problem,” said Ariel Dulitzky, the Clinic’s director. “They’ll say that everybody suffers from extreme heat, that it isn’t an issue particularly affecting inmates, and that there are other people in Texas that don’t have air conditioning either. So that’s their point, we all suffer.”

However, people outside of prison who experience extreme heat have options that prisoners often lack – they can take a cool shower, drink cold water, move into the shade or go to a place that is air conditioned. For prisoners, those options are generally unavailable.

It was U.S. District Court Judge Keith P. Ellison, a normally conservative jurist overseeing a lawsuit brought in 2014 by prisoners at the Wallace Pack Unit in Navasota, who ordered the TDCJ’s lawyers to disclose the number of heat-related prisoner deaths – something they had refused to do during the discovery process.

“We are not talking about how many widgets were sold out of a given factory,” Judge Ellison noted. “We are talking about human lives, and I would be very distressed if the answer is the TDCJ does not even keep count of how many people died of heat-related illness.”

The Pack Unit lawsuit was initially filed by seven prisoners who alleged the excessive temperatures they were forced to endure violated their constitutional rights, the Americans with Disabilities Act and the Rehabilitation Act. The unit mainly houses prisoners who are disabled, elderly or have medical conditions.

Attorneys Jeff Edwards and Scott Medlock with Edwards Law, along with the Texas Civil Rights Project (TCRP), represented prisoners in the Pack Unit suit. Edwards said extreme heat in the facility’s sheet-metal-clad housing units had “turned fraud ... [or] ... drunk driving into a death sentence.” He noted that “heads would roll and things would change” if the number of escapes from TDCJ prisons was as high as the number of heat-related deaths.

Edwards Law also represented the families of seven prisoners who died due to excessive heat, including Rodney Adams, who survived just two days after his 2012 arrival at the Gurney Unit in eastern Texas. At the time of his death, his body temperature had climbed to nearly 110 degrees.

The district court granted initial class certification in the Pack Unit case in June 2016, and that order was subsequently affirmed by the Fifth Circuit. See: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017).

In issuing an emergency injunction in July 2017 to lower temperatures at the Pack Unit, Judge Ellison expressed surprise that the TDCJ had no policy for taking action during a heat wave. He ordered prison officials to create such a policy within 15 days that would maintain housing areas for heat-sensitive prisoners at a heat index of no more than 88 degrees.

Heat index is a measure of heat and humidity that indicates what the air temperature feels like. During a heat wave in 2011 that killed 11 Texas prisoners, the outdoor heat index at the Pack Unit exceeded 100 degrees on 74 days. It was higher than 100 degrees on 73 days in 2013, and during 2014 it exceeded 100 degrees on 34 days and was between 90 and 99 degrees another 47 days. At some times, the heat index was higher inside two of the Pack Unit housing areas than it was outside.

As part of the injunction issued by Judge Ellison, prison officials were also ordered to provide uncontaminated drinking water at the prison, which contained two to four times the maximum amount of arsenic permitted by the Environmental Protection Agency. [See: PLN, Jan. 2017, p.10; Nov. 2016, p.22; Sept. 2015, p.12].

When the Pack Unit suit was filed, most of the 1,450 prisoners at the facility were heat-sensitive, including 188 older than 65 and 111 who were morbidly obese. There also were 728 who had hypertension, 142 with coronary artery disease, 53 who received prescribed psychiatric medications, 22 with liver cirrhosis, 84 with chronic obstructive pulmonary disease, 113 with asthma, 189 with thyroid dysfunction and 212 with diabetes. Many prisoners had more than one of those conditions.

Jennifer Erschabek, director of the Texas Inmate Families Association (TIFA), noted that prisoners who are heat-sensitive “need to be housed in a place where it’s not a life and death situation for them in the summer.”

In a July 2015 ruling in an appeal in the Louisiana death row heat case, the Fifth Circuit Court of Appeals lauded mitigation methods employed by prison officials such as the installation of fans and water misters, permitting prisoners to purchase personal fans from the commissary, allowing cool showers, providing cold drinking water and allowing heat-sensitive prisoners temporary relief in air-conditioned respite areas.

But according to the Centers for Disease Control, fans are ineffective at temperatures over 95 degrees and can actually increase body heat. Misters are also ineffective in areas with high humidity, where they can actually raise the heat index. Both cool-down showers and cold water are effective only for brief periods, and drinking large quantities of water can cause other medical complications.

Moreover, testimony revealed that respite areas at the Pack Unit were insufficient to house many of the heat-sensitive prisoners, who were discouraged from asking to use them. They were sometimes required to silently stand with their noses touching the wall, even if they were mobility impaired, or forced to submit to a measurement of core body temperature using a rectal thermometer before being allowed to go to a respite area.

During court hearings, Pack Unit prisoners testified they frequently experienced weakness, dizziness and nausea due to extreme heat conditions, which also made it hard for them to breathe. Neither party in the case contested whether excessive heat was a dangerous condition, but the TDCJ maintained that its heat mitigation efforts were sufficient.

Using harsh language, Judge Ellison rejected that argument and called prison officials “completely indifferent” to the plight of prisoners not young enough or healthy enough to benefit from heat mitigation measures at the facility.

Pack Unit Warden Robert Herrera was cited for obstruction for ordering the discontinuation of indoor heat index measurements in the prisoners’ living areas once the lawsuit was filed. The district court also chided TDCJ experts for exaggerating retrofit expenses that Texas Attorney General Ken Paxton called “unnecessary and not constitutionally mandated.” 

Prison officials had told the court it would cost $22 million to air condition the Pack Unit, which was built in 1983, plus another $500,000 in annual operating costs. Judge Ellison found an estimate presented by the plaintiffs – $450,000 up front and $175,000 per year thereafter – was more credible.

In addition to capping the prison’s heat index, the court also ordered the windows in housing units to be re-screened. Some dormitories lacked windows that opened while others did not have properly-fitting screens to keep insects out – leaving prisoners to choose between higher temperatures or insect infestations.

TDCJ officials installed the new screens and developed a heat wave policy. They first moved heat-sensitive prisoners at the Pack Unit to an air-conditioned gym at the facility, then began evacuating them to other prisons with air conditioning.

Transfers and Discovery Abuses

Judge Ellison approved a plan to temporarily move 562 Pack Unit prisoners to the Travis County State Jail near Austin, another 291 to the Diboll Correctional Center north of Houston, 122 more who required CPAP machines to the Mark W. Stiles Unit near Beaumont, and small numbers to various other prisons and medical units across the state.

A few hundred young, healthy prisoners remained at the facility. Other state prisoners displaced by the incoming heat-sensitive Pack Unit prisoners were sent to the Connally, Dalhart and Smith Units, located outside San Antonio, Amarillo and Lubbock, respectively.

In all, the TDCJ moved around 1,025 heat-sensitive prisoners to air-conditioned facilities in August 2017, and another 1,089 prisoners were transferred to make room for them. The move got even more complicated when Hurricane Harvey blew through southern Texas that same month, resulting in evacuations at three prisons when the Brazos River flooded its banks. [See: PLN, May 2017, p.48]. Hazardous road conditions forced state officials to send prisoners from the Stringfellow Unit in Rosharon to fill beds emptied at the Pack Unit.

In addition to the Pack Unit case, the U.S. District Court for the Southern District of Texas is also the venue for most of the 17 lawsuits related to excessive heat that have been filed against the TDCJ. One of those was a wrongful death complaint brought by the family of Robert Allen Webb, 50, a mentally-impaired prisoner at the Hodge Unit who was one of 11 prisoners to die during the 2011 heat wave – in his case, on a day when the heat index reached 104 degrees.

“They murdered my brother,” said Sidney Allen.

“Our case does not only concern the most vulnerable in TDCJ, it also concerns everyone in TDCJ because, at some point, it is our hope that the agency will join the 21st century,” said attorney Jeff Edwards. “It’s not only the inmates who are at risk. The officers are at significant risk.”

The TDCJ has paid over a half-million dollars in workers compensation claims to its employees for illnesses related to excessive heat since 2006. It has also spent $750,000 to air condition a building that houses hogs raised by prisoners – an expense that TDCJ spokesman Jason Clark defended by noting “pigs can’t sweat.”

Lance Lowry, who heads the union that represents TDCJ guards, observed that suicide attempts rise among prisoners every summer, as prisoners trying to avoid heat-related illnesses stop taking their psychotropic medications, thereby putting both themselves and staff at risk.

“I don’t have love for these people,” he said, referring to prisoners, “[but] the incarceration is their punishment, not cooking them to death.”

Since the TDCJ released a training video for guards in 2012 on how to spot symptoms of heat stroke, there have been no heat-related deaths in state prisons, Clark said – though the family of Quintero Devale Jones has debated that point in a wrongful death suit filed after he succumbed to an asthma attack during hot weather in 2015.

“Much like those Texans who do not have air-conditioning in their homes,” Clark stated, “[The TDCJ] uses an array of measures to keep offenders safe.”

Nevertheless, in January 2018, prison officials agreed to settlement talks in the Pack Unit suit, as well as in another case filed by Jeff Edwards on behalf of the families of three prisoners who suffered heat-related deaths in 2011 and 2012. The TDCJ’s decision followed a motion filed by Edwards to deny state prison officials a jury trial after it was revealed they had shredded inspection logs and prisoner grievances at the Gurney Unit.

Tod Gillam, a Gurney Unit risk manager, testified that he shredded the records shortly after he was hired in 2014 – which included evidence that Edwards said would have proven whether the deceased prisoners received water, working fans and other heat mitigation efforts. Gillam said he was never ordered to save the documents and, in fact, obtained a sign-off from the warden before disposing of six boxes of records and 40 computer disks. The TDCJ didn’t talk to Gillam about the improper destruction of the evidence until June 2017, and Edwards wasn’t informed until the following month.

Edwards also claimed in his motion that the TDCJ failed for years to share a 2011 email from a Palestine hospital that stated several prisoners who died had internal body temperatures over 105 degrees. The email’s recipient, a TDCJ regional director, had continued to deny that heat-related deaths were a widespread problem.

“At a minimum, it reflects absolute incompetence on the part of the agency and the fact that they failed to notify us upon learning about this abuse is particularly disturbing,” Edwards stated.

He argued that a jury could not weigh the lost records – so even if the case proceeded to trial, the court should instruct jurors to presume any missing evidence would have been favorable to the plaintiffs.

TDCJ spokesman Clark said the agency would “vigorously defend itself.”

The joint wrongful death suit was brought by family members of Gurney Unit prisoners Douglas Hudson, 62, and Kenneth Wayne James, 52, who died during the summer of 2011, and Rodney Adams, 45, who died due to heat exposure in mid-2012.

Edwards Law and the TCRP represented not only the families in the Gurney Unit lawsuit but also the survivors of Larry McCollum, who died at the Hutchins Unit in Dallas in 2011, and the families of other prisoners whose deaths were heat-related.

The TDCJ and University of Texas Medical Branch were sanctioned by a federal judge in the McCollum case in January 2015, and ordered to pay sanctions of more than $200,000 for not producing relevant documents and failing to investigate or interview crucial employees about events surrounding the 58-year-old’s death.

McCollum, a former cab driver who was serving time for passing bad checks, was found convulsing in his cell in July 2011. He arrived at a hospital with a body temperature of 109 degrees and was removed from life support six days later. Edwards said the TDCJ’s lawyers “didn’t do their job” with respect to disclosing evidence in the case.

“Memories fade, documents get destroyed and we didn’t have information at the time of depositions,” he noted.

Ashley Frantom, the daughter of deceased prisoner Rodney Adams, expressed her dismay with TDCJ officials. “It’s upsetting to know they’re hiding the truth,” she said.

Settlement in Class-action Lawsuit

In February 2018, the TDCJ announced it would install air conditioning in housing areas at the Pack Unit as part of a settlement reached in the class-action suit. Calling it “a big day for inmates who suffered,” attorney Jeff Edwards added, “they’re not going to be in fear of dying from heat stroke anymore.”

He said the TDCJ will install temporary air conditioners for use during the summer months in 2018 and permanent units by May 1, 2020, subject to legislative approval.

“The lawyers on each side took what was literally a life-and-death issue and worked cooperatively and effectively toward a resolution,” Judge Ellison declared – though it took four years of litigation to resolve the case.

Also in February 2018, the TDCJ began returning heat-sensitive prisoners who had been moved out of the Pack Unit six months earlier.

Judge Ellison entered final approval of the class-action settlement on June 8, 2018 after holding a fairness hearing in May. The agreement addressed injunctive relief and was signed by five of the six remaining named prisoner plaintiffs, including Jackie Brannum, Richard King, Michael Denton, Fred Wallace and Marvin Ray Yates. The sixth, Keith Cole, declined to sign and argued that class members should “have the opportunity to vote to approve the Settlement” – a suggestion nixed by the district court.

In settling the case, the TDCJ agreed to air condition prisoner housing areas at the Pack Unit and “maintain indoor heat indices at or below 88 degrees Fahrenheit between April 15 and October 15 each year.” Those measures will continue even if the class members are transferred to other facilities. Non-housing areas are not required to have air conditioning, such as the dining area, hallways and gymnasium.

When class members are transported to offsite medical appointments, prison officials will use air-conditioned vehicles; further, the TDCJ “will provide all conditional parole-voted programs” to class members in air-conditioned areas, except for the voluntary faith-based Innerchange Freedom Initiative program.

“Air-conditioning the housing areas of the Pack Unit will effectively protect Pack Unit residents from the dangers of extreme heat,” the court noted when approving the agreement. In case the heat rises above 88 degrees due to a failure of the air conditioning system, the TDCJ will notify class counsel and provide mitigation measures such as cool showers, cold drinking water and respite areas for prisoners.

The class members did not waive damages claims as part of the settlement, and the TDCJ agreed to pay $4.5 million in attorneys’ fees and costs to class counsel. Prisoners may opt out of the settlement if they choose to do so. In addition to Edwards Law and the Texas Civil Rights Project, the class members also were represented by the Houston law firm of Reynolds Frizzell LLP. See: Cole v. Collier, U.S.D.C. (S.D. Tex.), Case No. 4:14-cv-01698.

While the settlement only applies to prisoners housed at the Pack Unit, it may pave the way for changes at other TDCJ facilities.

“Obviously, if the inmates can prevail and get much needed protection from the heat in one prison, there’s significance to that for inmates everywhere,” said Edwards.

“I never dreamed we’d get air conditioning at the Pack Unit, and I believe it will benefit future generations of prisoners.... What we have done is extraordinary. It’s a new day in Texas prisons,” Judge Ellison declared.

In conjunction with the resolution of the Pack Unit class-action, settlement agreements were reached in eight other lawsuits involving TDCJ heat-related deaths and injuries. The settlements in those cases, in which the plaintiffs were represented by Edwards Law, included $900,000 for the death of Kenneth James, $475,000 for the death of Douglas Hudson and $750,000 for the death of Rodney Adams, who all died at the Gurney Unit. Additionally, the family of Larry McCollum received $905,000, and the TDCJ paid $600,000 for the death of Robert Allen Webb at the Hodge Unit; $500,000 for the death of Michael Martone at Huntsville; $450,000 to the family of Alexander Togonidze, who died at the Michael Unit; and $250,000 for the death of Albert Hinojosa at the Garza West Unit. TDCJ prisoner Brad Caddell, who survived a heat stroke at the Hutchins Unit, received $90,000.

“It’s been a privilege to represent the men at the Pack Unit and the families for quite some time and we’re pleased that we were able to get this result for our clients,” attorney Scott Medlock stated during an interview with Prison Legal News.

Continuing Heat Problems

Meanwhile, the family of Texas state prisoner Quintero Devale Jones continues to press its wrongful death suit following his fatal asthma attack, citing violations of the Americans with Disabilities Act as well as violations of his due process and equal protection rights.

Jones, 36, died during a July 2015 heat wave after guards at the McConnell Unit in Beeville confiscated his asthma inhaler and then ignored his pleas for help. The facility had already experienced at least three prisoner deaths due to heat stroke in 2004 and 2011.

“It’s unknown why they would not return to a prisoner an emergency breather that said ‘keep on person’ and they wouldn’t give it back,” said the family’s attorney, John Schulman.

Schulman noted that Jones’ asthma and hypertension, along with prescribed calcium channel blockers he was taking, put him at heightened risk of heat-related illness. Prison medical staff had seen Jones after asthma attacks on June 5, 2015 and July 28, 2015, and his medical records indicated he should keep his inhaler on him at all times and use it several times daily. The day he died, the heat index at the facility reached 110 degrees.

“I believe [TDCJ officials] clearly have a duty – not [to] provide him a comfortable and cushy experience, but certainly to protect his life,” Schulman stated. The case remains pending. See: Jones v. Livingston, U.S.D.C. (S.D. Tex.), Case No. 4:17-cv-02335.

In the lawsuit over excessive heat on Louisiana’s death row, the Fifth Circuit dealt a blow to the death-sentenced plaintiffs on January 31, 2018, reversing the district court and holding prison officials were not required to keep the heat index below 88 degrees. While a “temperature trigger” could be used to determine when heat relief measures are required, the appellate court held the establishment of a “temperature ceiling” was not allowed.

The district court had not ordered prison officials to install air conditioning, instead saying other means of reducing the temperature in cell blocks – such as providing prisoners with “IcyBreeze” ice chests – was adequate. However, the Court of Appeals found the district court had “effectively” required the installation of air conditioning by setting a heat index cap. The case remains pending on remand, but the Fifth Circuit specified the lower court “cannot decree whether any given plan is necessary to lower the heat index to below a maximum, nor can it require the state to provide an undetermined number of IcyBreeze units or other measures to keep the heat index below a certain point.” See: Ball v. LeBlanc, 881 F.3d 346 (5th Cir. 2018).

In 2017, an American Meteorological Society study warned that what we now call extreme heat will be commonplace as soon as 2020. But in Jefferson Davis Parish, Louisiana – where temperatures already exceed 90 degrees nearly one out of every four days – voters agreed to fund a new jail in 2014 only after local officials promised it would not have air conditioning.

“Climate control is not a matter of comfort and luxury,” said David Fathi, with the ACLU. “It’s a matter of life and death.”

And back at the Medium Security Institution (MSI) in St. Louis, Missouri – known locally as the city’s “workhouse” – a crowd gathered outside the jail on July 21, 2017 after a reporter from local news station Fox 2 News had earlier videotaped cries for help coming from prisoners inside the lockup, which lacked air conditioning.

State Senator Jamilah Nasheed joined the group of about 150 protesters. Carrying signs saying, “We treat animals better,” they chanted, “Let them go!” From inside the jail, prisoners responded with chants of “Let us out!” After about two hours, St. Louis police officers ordered the protestors to disperse; a few minutes later they pepper-sprayed the crowd.

One woman told Fox 2 News that her incarcerated grandson had reported temperatures of 109 degrees in his housing unit. A heat safety plan was in place at the time, according to St. Louis Corrections Commissioner Dale Glass, under which air-conditioned common areas like the cafeteria served as cooling stations and medical help was on standby. Mayor Lyda Krewson said prisoners also received wet towels, water, Gatorade, popsicles and ice to keep cool.

MSI holds 769 pre-trial detainees, most of whom are too poor to afford bail. The facility was the subject of a 2009 complaint filed by the ACLU that cited unsanitary conditions, inadequate medical care and assaults by guards – who allegedly organized gladiator-style fights between prisoners. The U.S. Department of Justice reported in 2013 that 6.3 percent of detainees at the facility were subjected to sexual abuse, one of the highest rates in the country.

A lawsuit filed on behalf of seven MSI prisoners on November 13, 2017 alleged the long-standing problems with sanitation, abuses and excessive heat at the jail had not been resolved and resulted in “hellish and inhumane conditions”; the complaint asked a federal judge to close MSI or fine the city $10,000 for each day it did not install permanent air conditioning or remediate mold problems. See: Cody v. City of St. Louis, U.S.D.C. (E.D. Mo.), Case No. 4:17-cv-02707-AGF.

In response, Commissioner Glass insisted “the jail is clean,” adding, “There’s no infestations, no mold, and the inmates are treated with respect.”

ArchCity Defenders, which filed the suit, worked with the St. Louis Action Council to raise about $10,000 that was used to bail out 15 MSI prisoners. State Rep. Joshua Peters sent a letter to House Speaker Todd Richardson asking for the formation of a special committee that would spearhead an investigation by the state’s Department of Health and Senior Services into MSI’s “deplorable and unsanitary health conditions.”

Mayor Krewson defended the jail, saying, “it’s not nice in there ... but it’s not deplorable.”

She also took credit for a decision to provide relief to MSI’s prisoners, after Board of Aldermen President Lewis Reed called for the use of temporary air conditioners until a more permanent solution to the extreme summer heat could be found. CBS affiliate KMOV reported that five 25-to-50-ton temporary AC units were quickly installed at the facility.

“I support air conditioning at MSI for the health and safety of everyone who is at that jail,” Mayor Krewson said in a statement. “Once my administration determined that temporary air conditioning was a viable solution, I ordered that temporary air conditioning units be installed as soon as possible.”

While that may have addressed heat-related issues at the workhouse in St. Louis, and the Wallace Pack Unit litigation in Texas resolved problems at that facility, prisoners in dozens if not hundreds of other prisons and jails – mainly spread across the southern states – can expect to have a hot summer in 2018. And hot summers during subsequent years, too, until corrections officials take meaningful steps to address extreme heat conditions. 

Sources: Houston Chronicle, Texas Tribune, The New York Times, New York Daily News,,,,,,,,,,,


Related legal cases

Cole v. Collier

Ball v. LeBlanc

Yates v. Collier

Jones v. Livingston

Cody v. City of St. Louis