Voices of the Experienced (VOTE) et al. v. James LeBlanc et al.
3:23-cv-1304
Rights Behind Bars, in collaboration with the Promise of Justice Initiative, has filed a groundbreaking lawsuit challenging the harsh and unconstitutional conditions of forced agricultural labor at the Louisiana State Penitentiary, known as Angola. This lawsuit brings together the collective efforts of grassroots nonprofit organization Voice of the Experienced (VOTE) and four incarcerated men currently at Angola, who represent all those compelled to work on the so-called “Farm Line.” Angola, once a plantation site, now spans 18,000 acres and forces incarcerated people, primarily Black men, into agricultural labor under oppressive conditions. These individuals toil in extreme heat and humidity, often lacking basic safety gear. This labor serves no legitimate purpose, with men forced to perform grueling tasks like digging and refilling holes or manually picking blades of grass.
The lawsuit asserts violations of the Eighth Amendment, the Americans with Disabilities Act, and the Rehabilitation Act. The case is a putative class-action on behalf of all people forced to work the Farm Line with two sub-classes: people with disabilities and people convicted by non-unanimous juries. Discrimination against people with disabilities is a consequence of the extreme conditions of the Farm Line. Every person incarcerated at Angola is at risk of serious harm due to their exposure to extreme heat during the summer months in Louisiana. This is especially true for people with medical or mental health conditions, or who are taking certain medications, that make them more susceptible to heat-related injuries. In addition to incorporating these allegations into the lawsuit, we have also asked the US Department of Justice to investigate this matter.
This lawsuit introduces a novel argument under the Thirteenth Amendment: individuals convicted by non-unanimous juries should not be subjected to forced labor. This is especially significant given Louisiana's history of allowing non-unanimous jury convictions, a practice deemed unconstitutional in Ramos v. Louisiana by the U.S. Supreme Court. The Thirteenth Amendment only permits forced labor for those "duly convicted." Hence, individuals convicted by non-unanimous juries are legally exempt from forced labor under this constitutional provision.
Rights Behind Bars and partners filed an emergency motion requesting a preliminary injunction and temporary restraining order to prevent Angola from operating the Farm Line when the heat index reaches or exceeds 88 degrees. Federal Judge Brian Jackson responded by ordering state officials to immediately rectify the “glaring deficiencies in their heat-related policies” at the facility, marking a victory for temporary relief from forced labor in life-threatening extreme heat.
Judge Jackson indicated he is taking the threat posed by the Farm Line seriously, setting a trial date of September 30 for the ongoing class action lawsuit.
Read our Filings:
Motion for a Preliminary Injunction and Temporary Restraining Order