Law360 (May 27, 2026, 5:38 PM EDT) -- A federal court ruled that forced agricultural labor at Louisiana State Penitentiary does not violate federal law, leaving intact a form of punishment that prisoners and critics say exposes workers to degrading and unsafe conditions.

Following a five-day bench trial in February, U.S. District Judge Brian A. Jackson for the Middle District of Louisiana found Tuesday that incarcerated workers at what is known as the prison's Farm Line face serious risks from extreme heat and that prison officials knew the danger began well below the prison's official threshold for halting work — yet the judge still declined to permanently stop the practice, saying changes the state implemented barred relief.

Judge Jackson said in his 60-page ruling that the plaintiffs — a group of current Farm Line workers who filed a class action — could not show that prison officials subjected them to harsh labor conditions with the type of "recklessness" associated with criminal acts, a standard required by recent Fifth Circuit precedent.

"But because defendants have taken remedial measures to cure some of the risks incarcerated men face when working on the Farm Line, such measures, according to the circuit, apparently 'negate' a finding of subjective indifference," Judge Jackson wrote.

The court emphasized the plaintiffs had met their burden in showing that working conditions at the prison, which is known as Angola, posed a substantial risk of serious harm and possibly violated the Eighth Amendment's prohibition against cruel and unusual punishments.

But then it clarified that the Fifth Circuit's March ruling in Parker v. Hooper, a case involving the constitutional adequacy of medical care provided to people incarcerated at the prison, "appears to have raised the standard" that plaintiffs must meet to win a permanent injunction from a federal court.

Samantha Kennedy, the executive director for The Promise of Justice Initiative, a nonprofit that spearheaded the litigation alongside Right Behind Bars, said the ruling "turns a blind eye" to the history of subjugation marring Angola, which sits on the grounds of a former slave plantation.

"The court's failure to issue relief means that today in Louisiana, the state can continue to subject incarcerated people, Black men in particular, to egregious physical and psychological harm," Kennedy said in a statement. "In a time when courts and lawmakers across the South are taking away the rights of Black people, this ruling turns a blind eye to the history of subjugation experienced by our ancestors under chattel slavery on the very plantation on which Angola sits."

The class action was filed in September 2023 by Voice of the Experienced, an advocacy group led by formerly incarcerated people, along with several men incarcerated at Louisiana State Penitentiary, challenging conditions on the Farm Line.

The plaintiffs allege that incarcerated workers were forced to labor in extreme heat with inadequate shade, water, rest and medical protections, in violation of the Eighth Amendment and the Americans with Disabilities Act.

The litigation quickly evolved into a prolonged fight over emergency heat protections. Beginning in May 2024, Judge Jackson issued a series of temporary restraining orders and preliminary injunctions requiring prison officials to improve shade and protective equipment, expand medical precautions for heat-sensitive prisoners, issue "Heat Alerts" when the heat index exceeded 88 degrees and monitor heat conditions on the Farm Line.

Louisiana officials repeatedly appealed those orders to the Fifth Circuit, which stayed or vacated portions of the relief while directing the case toward a full merits trial.

After the court certified a general Farm Line class and a disability subclass in late 2025, the case proceeded to trial in February, where the plaintiffs presented evidence that incarcerated workers were forced to perform agricultural labor in dangerous heat and humidity without adequate breaks, medical accommodations or safety protections, while under constant supervision by armed guards and overseen by a "line pusher."

While the litigation continued, prison officials implemented a series of reforms, including installing permanent shade pavilions, expanding heat precaution policies and adopting new weather-monitoring systems and revised work-rest procedures.

On Tuesday, Judge Jackson found that, although incarcerated workers still faced a substantial risk of serious harm from extreme heat, the state's ongoing remedial efforts prevented plaintiffs from being entitled to a permanent injunction from the court that would have imposed additional restrictions on Farm Line work.

The court emphasized that plaintiffs had shown Farm Line workers faced a substantial risk of serious harm from extreme heat but held that recent remedial measures prevented a finding of ongoing deliberate indifference.

The Promise of Justice Initiative said in a press release that the improvements to working conditions, including shaded rest areas, water breaks and expanded protections for heat-sensitive individuals, were hard-fought wins resulting from more than three years of litigation.

"Because the court declined to order permanent relief, the Louisiana Department of Public Safety & Corrections, an agency that has repeatedly shown a callous disregard for those in its care, may reverse those changes," the nonprofit said.

Terrance Winn, a formerly incarcerated advocate who spent three decades at Angola, where he was forced to work the prison farm line, reacted with dismay to the ruling.

"Disheartened does not begin to capture the emotions I'm feeling about this ruling. But we as Black people have long been conditioned to expect the courts to rule against us," he said in a statement. "[In Angola] so many men choose to go to solitary confinement rather than working in the fields. People would rather lose their minds than endure the Farm Line. To the men still being punished inside Angola: We can't give up. Our voice is our hope. We have to continue to believe and push: We can end this form of slavery."

Samuel Weiss, the executive director of Rights Behind Bars, called the Farm Line "dangerous, pointless, and cruel."

"The state of Louisiana fought tooth and nail to be allowed to continue using forced labor as punishment, knowingly risking lives in the process," Weiss said in a statement. "They should have ended the operation of the Farm Line long ago."

The plaintiffs are represented by Claude-Michael Comeau, Samantha Bosalavage Pourciau, Michael Allen and Cecelia Trenticosta Kappel of The Promise of Justice Initiative, Oren Nimni and Samuel Weiss of Rights Behind Bars and Jeremy A. Benjamin, Christopher Bilicic, Joshua Hill Jr., Janet Lee, Arielle B. McTootle, Erica M. Paul, Ricardo R. Sabater, Leah Weiser and Chizoba D. Wilkerson of Paul Weiss Rifkind Wharton & Garrison LLP.

The defendants are represented by Andrew Blanchfield, Christopher K. Jones, Crews Reynolds LeBlanc Jr. and Chelsea Acosta Payne of Keogh Cox and Caitlin A. Huettemann of the Office of the Louisiana Attorney General.

The case is Voice of the Experienced et al. v. James LeBlanc et al., case number 3:23-cv-01304, in the U.S. District Court for the Middle District of Louisiana.

--Editing by Dave Trumbore.

For a reprint of this article, please contact reprints@law360.com.