Angola Farm Line lawsuit will determine if forced prison labor is unconstitutional

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Because Farm Line workers are captive men forced to work for little or no pay under the supervision of armed guards on horseback, the practice is often described as a modern form of slavery.

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In December, U.S. District Judge Brian A. Jackson certified the case, Voice of the Experienced (VOTE) vs. LeBlanc, as a class-action lawsuit, with a class made up of incarcerated men assigned to the Farm Line, including a subclass of people with disabilities.

The class certification marks a critical turning point in the case because it allows the court to address the Farm Line as a systemwide practice rather than a series of individual claims, attorneys for the incarcerated men said.

“Class certification is a major step toward protecting the constitutional rights of everyone incarcerated at Angola,” said Lydia Wright, legal director of Rights Behind Bars, who is representing the Farm Line along with lawyers from the Promise of Justice Initiative. “The state’s operation of the Farm Line is dangerous, pointless and cruel. It endangers every person incarcerated at Angola.”

Any remedy ordered in the case would also apply throughout the Farm Line, including those who may be assigned there in the future, said Wright, acknowledging the suit’s seven original named plaintiffs, who brought the case in September 2023 along with the group Voice of the Experienced, which advocates for people who are or have been incarcerated.

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In rulings that started in July 2024, Jackson ordered officials at the Louisiana Department of Public Safety and Corrections to “correct the glaring deficiencies in their heat-related policies.” To inform that decision and other subsequent rulings, Jackson has visited Angola and read through hundreds, perhaps thousands, pages of heat-related policies and related reports.

To date, Jackson’s rulings have focused largely on immediate dangers faced by the Farm Line, particularly exposure to extreme temperatures above an 88-degree “heat index,” a measure that incorporates both temperature and humidity.

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But Jackson has not yet addressed the lawsuit’s central contention: that the Farm Line is unconstitutional. That issue will be addressed in the five-day trial that started Tuesday, Feb. 3, in the U.S. District Court for the Middle District of Louisiana in Baton Rouge.

During the trial, the Farm Line’s very existence will be called into question, Wright said.

“The certified classes challenge the Louisiana State Penitentiary’s operation of the Farm Line, 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,” Wright said.

The Farm Line constitutes cruel and unusual punishment in violation of the Constitution’s Eighth Amendment, said Wright, who quickly summarized the suit’s arguments about that matter:

1) “Defendants force men to labor on the Farm Line under high heat conditions that expose them to a substantial risk of serious physical harm without adequate mitigation to abate that risk,” Wright said.

2) “Defendants use the Farm Line to punish men by subjecting them to debasing, inhumane conditions reminiscent of chattel slavery, thereby stripping them of their fundamental human dignity, deviating from contemporary standards of decency, and adding degradation on top of their sentence to hard labor,” Wright said.

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The lawsuit also alleges that the Farm Line violates federal disability laws including the American Disabilities Act and Section 504 of the 1973 Rehabilitation Act, because prison officials fail to properly accommodate people who could sustain grave injuries or die if exposed to heat.

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