by Chuck Sharman

On December 23, 2025, the U.S. District Court for the Middle District of Louisiana granted class certification to a suit challenging the constitutionality of the “farm line” work program at the Louisiana State Penitentiary (LSP) at Angola. The ruling allows claims from the seven named Plaintiffs to proceed on behalf of more than 4,000 prisoners held at the lockup—many of whom are subject to assignment to grueling agricultural labor, testimony showed.

The suit was filed in September 2023 by the nonprofit advocacy group Voice of the Experienced (VOTE) for the seven prisoners: Myron Smith, Damaris Jackson, Nate Walker, Darrius Williams, Kevias Hicks, Joseph Guillory and Alvin Williams. They claimed that forcing prisoners to work on the “farm line” not only endangers their health in oppressive heat—which prevails through much of the year—but is imposed for punitive purposes, violating the Eighth Amendment guarantee of freedom from cruel and unusual punishment.

The district court granted a preliminary injunction and temporary restraining order (TRO) on July 2, 2024, ordering officials with the state Department of Public Safety & Corrections (DPSC) to make provisions for prisoners on the “farm line” to have access to water, shade and rest, as well as sunscreen and other protective equipment. Defendants were also ordered to identify prisoners suffering health conditions or using medications that diminished bodily “thermoregulating” capacity and ensure they were granted “heat precaution duty status.” Enhanced measures to protect prisoners from heat were required whenever the outdoor heat index reached 113 degrees Fahrenheit. See: Voice of the Experienced v. LeBlanc, 2024 U.S. Dist. LEXIS 118117 (M.D. La.).

Defendants turned to the U.S. Court of Appeals for the Fifth Circuit, but it declared the appeal moot on August 5, 2025, since the TRO had expired 90 days after it was issued, as dictated by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e. Citing the principle laid out in United States v. Munsingwear, Inc., 340 U.S. 36 (1950), the appellate Court also issued vacatur of the injunction. See: Voice of the Experienced v. Westcott, 2025 U.S. App. LEXIS 19701 (5th Cir.).

Meanwhile, the district court issued a second TRO on May 23, 2025, ordering DPSC officials to issue a “heat alert” whenever the heat index reached 88 degrees Fahrenheit and monitor it every 30 minutes thereafter. Defendants once again appealed to the Fifth Circuit. While the appeal was pending, Plaintiffs moved to renew the TRO when it expired, which the district court largely granted on August 22, 2025. See: Experienced v. LeBlanc, 2025 U.S. Dist. LEXIS 163943 (M.D. La.).

The Fifth Circuit dismissed Defendants’ appeal of the May 23 order on August 28, 2025, again finding it mooted by the PLRA’s 90-day automatic TRO expiration requirement and vacating the injunction, as per Munsingwear. They also appealed the August 22 order, but the Fifth Circuit dismissed that appeal on November 21, 2025, citing the same reasons. See: Voice of the Experienced v. LeBlanc, 2025 U.S. App. LEXIS 22204 (5th Cir.); and 2025 U.S. App. LEXIS 30664 (5th Cir.).

Plaintiffs asked for another injunction and TRO, but the district court denied the request on December 4, 2025, reasoning that the case should go to trial before the heat returned in spring 2026. See: Experienced v. LeBlanc, 2025 U.S. Dist. LEXIS 251725 (M.D. La.).

Class Certification Granted

The district court’s December 23 order certified a “general class” consisting of all prisoners who currently are or will be incarcerated at LSP and forced to work on the “farm line.” As Plaintiffs have repeatedly argued, the work assignment is considered a punishment—hence their constitutional challenge to it—and guards can inflict it on almost any prisoner at any time with little justification or warning.

The ruling also certified an “ADA subclass” including those Plaintiffs who suffer from “disabilities that substantially limit one or more of their major life activities,” as defined by the Americans with Disabilities Act (ADA), 42 U.S.C. § 12131 et seq. and Section 504 of the Rehabilitation Act, 29 U.S.C. § 701 et seq.

In its ruling, the district court found that the two classes met the requirements for numerosity and commonality of legal issues they face, as well as typicality and adequacy of the named Plaintiffs to serve as Class Representatives. Approved to provide Class Counsel were attorneys for Plaintiffs from VOTE and the Promise of Justice Initiative, both in New Orleans; Rights Behind Bars in Washington, D.C.; and Paul, Weiss, Rifkind, Wharton & Garrison LLP in New York City and San Francisco.

Trial in the case began before U.S. District Judge Brian A. Jackson on February 3, 2026. He seemed skeptical of a claim by DPSC attorney Andrew Blanchfield that maintaining an 88-degree heat index ceiling would not only “end” the farm line but also “end” LSP. According to The Advocate, Blanchfield told Jackson that “you have almost half of the prison population with heat-precaution duty statuses … [s]o if you say that when the heat-index hits 88, everything outside stops, that’s going to put such a hamper on LSP. We’ve got a lot of stuff going on in the afternoons outside.”

That “stuff” also includes prisoner medical emergencies, which occur around four or five times daily on the “farm line” during the hottest weather, Rights Behind Bars Legal Director Lydia Wright told the Louisiana Illuminator. She called the work assignment “an unlawful, degrading, and dangerous disciplinary practice through which the state compels incarcerated men at Angola to labor under conditions designed to replicate aspects of chattel slavery.”

Angola rests on the site of an antebellum cotton plantation; and two-thirds of DPSC prisoners held at the end of 2025 were Black. PLN will continue to update case developments as they unfold. See: Voice of the Experienced v. LeBlanc, USDC (M.D. La.), Case No. 3:23-cv-01304.  

Additional sources: The Advocate, Louisiana Illuminator

Subscribe today

Already a subscriber? Login

Related legal case