Paul, Weiss Obtains TRO to Protect Men Forced to Labor in Extreme Heat on Angola’s “Farm Line”

On behalf of a putative class of people incarcerated at Louisiana State Penitentiary, also known as ”Angola,” Paul, Weiss, alongside co-counsel Promise of Justice Initiative and Rights Behind Bars, obtained a temporary restraining order (TRO) that requires prison officials and the Louisiana Department of Public Safety and Corrections to immediately implement health and safety measures intended to protect incarcerated men assigned to the “Farm Line” from heat-related injury. Specifically, the defendants must issue a “heat alert” whenever the heat index meets or exceeds 88 degrees Fahrenheit and monitor heat conditions every 30 minutes. The alert triggers other mandatory precautionary measures, including bringing heat-sensitive people inside and implementing regularized work breaks.

Built on the grounds of former slave plantations, Angola began functioning as a prison agricultural complex shortly after the end of the Civil War. Today, men on Angola’s Farm Line – most of whom are Black – are forced to labor in those same plantation fields, harvesting crops without even basic tools or adequate protective gear, while surrounded by armed guards and overseen by a “line pusher.” They earn from zero to four cents per hour. If they refuse to work, or don’t work fast enough, they face solitary confinement. These inhumane conditions become even more dangerous in the notorious Louisiana heat and humidity.

Our clients, Voice of the Experienced and seven men incarcerated at Angola, seek to end the Farm Line, asserting claims under the Eighth Amendment, the Americans with Disabilities Act and the Rehabilitation Act. While pursuing that relief, the plaintiffs, on behalf of themselves and putative class members, have twice sought preliminary heat-related relief, first in May 2024, and again in March 2025.

The May 23 TRO marks the second consecutive year that the Middle District of Louisiana has ordered preliminary relief to protect men on the Farm Line from heat-related injury. Last summer, the court issued a preliminary injunction requiring prison officials to take a series of remedial measures at a time when prison policies required heat alerts to issue whenever the heat index exceeded 88 degrees. After that injunction expired last fall, prison officials revised their heat pathology protocols, including a provision that raised the heat alert threshold from a heat index exceeding 88 degrees to one exceeding 91 degrees. Plaintiffs moved to enjoin that change and force other protective measures.

In his TRO, U.S. District Judge Brian Jackson noted that, “[i]ncredibly, although the Court found that Defendants’ proposed remedies to address the threat to human health and safety on the Farm Line ‘border[ed] on bad faith,’ Defendants nonetheless chose to raise the Heat Alert threshold in effect as of the Court’s July 2 [, 2024] Order.” The court found that our clients had demonstrated through credible expert testimony, scientific support and relevant agency guidance, the appropriateness of the lower, 88-degree threshold. By contrast, the court found the defendants’ expert “wholly uncredible,” and held that our clients had demonstrated a likelihood of success on their claims that defendants were acting with deliberate indifference.

The Paul, Weiss team is supervised by litigation partner Joshua Hill, and includes pro bono counsel Jeremy Benjamin, litigation counsel Michael McGregor, and associates Christopher Bilicic, Kimberly Grambo, Janet Lee, Arielle McTootle, Kirk McLeod, Erica Paul, Ricardo Sabater, Leah Weiser and Chizoba Wilkerson.