For nearly 30 years, Terrance Winn's days began the same way. At 5 a.m., prison guards at Louisiana State Penitentiary, better known as Angola, would blow a whistle, turn the lights on and shout at the inmates to get up.

Then, he and the 90-some men who shared his open-bay dormitory would line up to use the six open toilets available to them, brush their teeth, wash their faces and get ready for the long day ahead.

Winn and his fellow prisoners would exit the prison building with tools in their hands, walking in a double line behind an armed prison guard mounted on a horse into the vast grounds of Angola. The prison sits on a former slave plantation along the Mississippi River and is now the largest maximum-security prison in the United States.

In humid air and scorching sun, Winn and his fellow prisoners toiled over the fields of crops in what is known as the Farm Line. Watched by armed guards trained to shoot to disable, and to kill if deemed necessary, Winn said the parallel with slavery was immediately apparent to him.

"I don't think of it as a parallel. It's one and the same," he said. "You know, being in prison is actually slavery, it's nothing different."

In December 1989, Winn was detained for shooting a man during a fight on Christmas night, killing a bystander. He was later convicted and sentenced to life in prison without possibility of parole at age 16. He was released on parole in July 2020, after the U.S. Supreme Court ruled in 2012 and 2016 that mandatory sentences of life without parole for defendants who were under 18 at the time of their crime are unconstitutional.

While living behind bars was challenging, Winn said, the hardest aspect of his imprisonment was working the Farm Line.

"Three-hundred-sixty-five days a year, you're forced to keep that farm being productive," he said. "You're doing backbreaking work, you're working in the sun, working in the cold, you're working every season, but you're not receiving anything from this."

Winn's experience mirrors that of many incarcerated men who continue to work the Farm Line today. Those incarcerated workers are represented in a class action that challenges the prison's forced labor practice as unconstitutional.

Since he's no longer incarcerated, Winn is not a part of the lawsuit. But as a leader within Voice of the Experienced, or VOTE, a grassroots organization of currently and formerly incarcerated people that is a party to the litigation, he remains in regular contact with people at Angola and has become one of the most visible public voices describing life on the Farm Line.

On May 26, following a bench trial in February, a federal judge found that Louisiana prison officials knowingly exposed Farm Line workers to dangerous heat conditions, yet concluded that, under Fifth Circuit case law, reforms adopted during the litigation rendered permanent injunctive relief unnecessary.

In the decision, U.S. District Judge Brian A. Jackson for the Middle District of Louisiana said his hands were tied by the precedent established in March by the U.S. Court of Appeals for the Fifth Circuit in Parker v. Hooper, a ruling in a class action alleging that medical care at Angola was constitutionally deficient. Judge Jackson said that ruling required courts to consider whether prison officials had reasonably responded to known constitutional risks before ordering further relief.

Advocates decried Judge Jackson's decision at a press conference in New Orleans the following day, saying the labor system on the Farm Line "reinforces slavery as a way of life" and calling the ruling "heartbreaking."

"Angola was delivered a loss, but no consequences," Samantha Kennedy, the executive director for the Promise of Justice Initiative, said from a podium. "It is wholly insufficient and not the way we ought to live in a country where people are supposed to have rights."

A "Victory Without Remedy"

Farm Line workers help deliver a wide variety of crops on the approximately 3,000 acres of cultivated land at Angola. Soybeans, corn, peas, watermelons, tomatoes, strawberries, cucumbers, sugar cane, squash, eggplant, cabbage, mustard greens, turnip greens, broccoli, cauliflower and cotton are planted, cared for and harvested there, according to Winn.

The produce gets shipped to various prisons around Louisiana, which has one of the highest incarceration rates in the world. The labor force behind that production is made up almost entirely of incarcerated people who, after three initial years working unpaid, earn 2 to 4 cents per hour. A separate for-profit agricultural operation run by Prison Enterprises, a state correction department subdivision, grows crops that are sold in the open market.

The lawsuit, which targets only the punitive portion of the Farm Line, was filed in September 2023 by VOTE and several incarcerated plaintiffs, who alleged that conditions on Angola's Farm Line violated the Constitution and federal disability law. They are represented by the Promise of Justice Initiative and Rights Behind Bars.

In the complaint, which sought to end compulsory work on the Farm Line, attorneys said that four initial name plaintiffs — Myron Smith, Damaris Jackson, Nate Walker and Darrius Williams — and many other people like them, are forced to perform manual agricultural labor for hours on end, using hand tools and outdated equipment, often without adequate access to drinking water, shade, toilet facilities, training or protective gear.

Particularly in the summer, with a mix of high temperatures and humidity, prolonged outdoor agricultural labor puts people at risk of death or permanent physical injury, due to dehydration, hyperthermia and other serious medical complications. Those risks are even higher for people who, because of various disabilities, lack the capacity to regulate their internal body temperature, the complaint says.

The Louisiana Department of Public Safety and Corrections did not respond to a request for comment.

The state has consistently defended the Farm Line as a constitutional prison work program and argued that prison officials have implemented extensive safeguards to protect incarcerated workers from heat-related illness. In a post-trial brief, attorneys for the state pointed to measures including regular rest breaks, shaded cooling areas, unrestricted access to water and Gatorade, and emergency medical response protocols as proof that prison officials were responding reasonably to heat-related risks and that further court intervention was unnecessary.

"LSP has exceeded constitutional requirements and guidelines for private employers to protect all offenders from heat related issues," the brief says, referring to the prison.

They also disputed plaintiffs' contention that the Farm Line lacks a legitimate purpose, noting that crops harvested there are used to feed incarcerated people and citing Fifth Circuit precedent recognizing prison work as a means of offsetting costs, maintaining order and preparing people for life after release.

In their filings, attorneys for the plaintiffs argued that after slavery was formally abolished, Louisiana used discriminatory "Black codes" — precursors of the Jim Crow laws — and aggressive criminal enforcement to expand its prison population, particularly with Black people, creating a new source of coerced labor for the state.

The attorneys traced Angola's origins back to the convict leasing era when, beginning in the 1840s in Louisiana, state and local governments leased incarcerated people to private individuals, planters and corporations. The attorneys described that system as even more brutal than slavery because incarcerated workers were considered expendable rather than valuable property. Louisiana banned convict leasing beginning in 1901, though it lingered at Angola for more than a decade.

That fundamental labor system remained intact after the state purchased Angola in 1901 and converted it into the Louisiana State Penitentiary, making the state the beneficiary of the imprisoned labor. In the decades that followed, mass incarceration ensured a steady supply of free labor, disproportionately coming from Black workers, the complaint says.

Attorneys called work on the Farm Line "pointless" and said that many daily tasks assigned to incarcerated men — like watering crops using a Styrofoam cup or pulling blades of grass by hand — are designed to enforce powerlessness.

"This definitionally pointless labor—extracted under threat of further punishment and serious harm—is humiliating and degrading," the complaint says. "This labor serves no legitimate penological or institutional purpose. It is purely punitive, designed to 'break' incarcerated men and ensure their submission."


Through claims brought under the federal civil rights statute — Section 1983 of Title 42 of the U.S. Code — the plaintiffs accused the Louisiana Department of Public Safety and Corrections, former Secretary James LeBlanc, and former Angola Warden Timothy Hooper of violating incarcerated workers' Eighth Amendment right to be free from cruel and unusual punishment.

The officials were also alleged to have violated the Americans with Disabilities Act and Rehabilitation Act by failing to make accommodations for people with disabilities and health conditions, forcing them to work in the fields with the broader group of prisoners.

During the course of pretrial litigation, the plaintiffs secured multiple preliminary injunctions that led to longer breaks, improved access to water, shade and protective equipment, more frequent heat monitoring, and a significant expansion of the prison's list of heat-sensitive prisoners.

The state pointed to those changes in an effort to end the case as moot.

On Dec. 23, Judge Jackson certified the class action, recognizing two classes: a general class consisting of all people incarcerated at Angola who are or may be assigned to the Farm Line, and a subclass of current or possible Farm Line workers who have disabilities.

During the five-day trial in February, the plaintiffs' attorneys called 18 people to the stand, including five incarcerated individuals who gave personal accounts of their exhausting, continuous physical and mental labor on the Farm Line. One of them, Joseph Guillory, testified about being asked to water crops with a cup, which he described as "a waste of time," under the threat of discipline.

"The sun's burning you up out there," he said. "It makes it harder for you to breathe."

On the stand, he recalled how he felt when tour buses periodically drove by the incarcerated workers, as passengers waved and took pictures of the workers drudging over their work.

"The state really just — They really just egging you on, like a show," he said, according to trial transcripts. "You putting on a show. You've got me out here, I'm slaving out here. I don't know what I'm doing, but I'm doing it anyway. And you've got people just passing by like I'm entertainment."

Another inmate, Myron Smith, testified about a guard pointing a rifle at a group of workers, apparently for not moving fast enough while en route to the fields.

"'Tighten the fucking line up,'" Smith recalled the guard yell. "He cocked his gun and he pointed it at us."

Four expert witnesses testified about heat-related injuries, prison agriculture and the history of Angola. Several of them opined that the Farm Line's structure and practices evoke the cultural memory of slavery and function as part of the punishment imposed on incarcerated workers.

Ultimately, Judge Jackson found that incarcerated workers continued to face a substantial risk of serious harm from extreme heat, but determined that the ongoing reforms at Angola prevented the plaintiffs from obtaining a permanent injunction requiring further restrictions on Farm Line labor.

"This litigation has obtained the relief Plaintiffs seek—more significant protections for incarcerated persons laboring on the Farm Line," he said in his order, which also acknowledged the "apparent willingness" of present Angola Warden Darrel Vannoy to "take seriously" the concerns raised by the plaintiffs and work toward solutions.

While acknowledging the material gains for people incarcerated at Angola obtained in response to the litigation, the plaintiffs and their attorney expressed dismay at the ruling, saying it didn't go far enough.

"This is a victory without a remedy," Promise of Justice's Kennedy said.

In a statement days after the ruling, Guillory said he was thankful some of the Farm Line practices were "corrected and changed," but added that the ruling did not remedy what he sees as a degrading culture at the prison.

"They can build a shade pavilion, OK, but what about the mindset? What about the way they talk to you? What about the things they tell you to do?" he said. "They want to break your spirit. They want to break you down. You just become a slave."

The Debate the Court Didn't Acknowledge

Congress outlawed slavery and involuntary servitude by enacting the 13th Amendment in 1865, but the amendment contains a clause that permits the practices as a punishment for crimes for people who "have been duly convicted." The so-called punishment clause effectively permits states to subject incarcerated people to forced labor.

In 2020, in Ramos v. Louisiana, the U.S. Supreme Court held, by a 6-3 vote, that the Sixth Amendment requires unanimous jury verdicts in state criminal trials for serious offenses, just as it does in federal court. At the time, only Louisiana and Oregon still permitted nonunanimous juries.

In May 2021, however, the Supreme Court held in Edwards v. Vannoy that the Ramos decision did not apply retroactively, though it left the door open for states to devise mechanisms to grant retroactive relief. The Louisiana Supreme Court held in 2022, in State v. Reddick, that the relief in Ramos was only forward-looking.

Earlier in the Angola litigation, the plaintiffs' attorneys sought the recognition of a second subclass made up of people who were convicted by nonunanimous juries, arguing that the state of Louisiana is violating 13th Amendment rights by forcing them to work on the Farm Line without "being duly convicted" under the meaning of the Ramos decision. The attorneys argued that the Reddick ruling only applied to claims under the Sixth Amendment, in which convicted people usually seek new trials, but not to 13th Amendment claims.

Judge Jackson agreed with the state that the case law barred the plaintiffs' 13th Amendment claim, and tossed it from the suit while also rejecting the proposed subclass.

In his ruling last month, Judge Jackson never once mentioned slavery or the connected psychological harm, or dignitary harm that the plaintiffs alleged they endured while working the Farm Line.

"The court was simply silent," Kennedy said.

This point is central in the plaintiffs' bid for reconsideration of the ruling.

On Tuesday, they filed a motion asking Judge Jackson to reconsider his May decision, arguing that the court failed to address what they describe as the case's central Eighth Amendment claim: that Angola's Farm Line inflicts a distinct dignitary harm rooted in the prison's history as a former slave plantation.

In the motion, the plaintiffs noted that the words "dignity" and "slavery" do not appear anywhere in the ruling despite extensive testimony and expert evidence on the issue. They also contend that Judge Jackson misread the Fifth Circuit's decision in Parker, arguing that the ruling requires courts to consider whether prison officials reasonably responded to known risks, not automatically deny relief whenever corrective measures have been implemented.

Samantha Pourciau, a senior staff attorney at Promise of Justice, told Law360 that the court committed a "manifest error" by failing to address extensive evidence concerning the psychological and dignitary harms plaintiffs say are associated with compulsory agricultural labor at Angola.

"We're hopeful that the court will take our opportunity, our request here to reconsider, to confront what we see as the central claim of this case, the dignitary harm theory that motivated us to bring this case in the first instance: to expose that direct throughline from chattel slavery to modern-day mass incarceration, and the reality that modern-day slavery is happening at Angola Prison," Pourciau said.

Celina Chapin, the chief advocacy officer at Worth Rises, a nonprofit advocacy group that campaigns against what it describes as prison industry exploitation and supports efforts to end the 13th Amendment's exception permitting involuntary servitude as punishment for crime, told Law360 that the ruling carries significance beyond Angola because incarcerated people continue performing agricultural labor under dangerous conditions at prisons across the country.

"Angola is not the only place that's doing this," Chapin said, pointing to prison agricultural operations in Texas, for example, where incarcerated workers continue harvesting crops under conditions she said are reminiscent of earlier forms of coerced labor. Nine out of 24 prison units that have agribusiness operations in the Lone Star State are located on former plantations, she said.

"What we have in this country is not prison labor, it's prison slavery," she said, contending that the constitutional carveout has allowed prisons to compel labor while denying incarcerated workers many of the protections available to employees outside prison walls.

She also emphasized that advocates are not necessarily seeking to eliminate prison work altogether. 

Many prison labor reform advocates, she added, support opportunities for incarcerated people to work and develop skills, but want those workers to be treated "as workers and not as slaves."

"I think we have found over and over again that incarcerated people want to work, and there is dignity in work, but there is no dignity in slavery," Chapin said.

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 Alex Hubbard and Orlando Lorenzo. Graphics by Jason Mallory.

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