Three death row inmates at Angola filed suit against the Louisiana Department of Corrections and various officials alleging that the lack of air conditioning on death row amounted to a violation of the Eighth Amendment, the Americans with Disabilities Act, and the Rehabilitation Act. The inmates argued that their health conditions were made worse by high temperatures, and that their being kept in hot cells amounts to cruel and unusual punishment. The trial court ruled in favor of the Eighth Amendment claim but rejected the disability claims. The trial court also issued an injunction effectively requiring the installation of air conditioning throughout the death row. The injunction required that the entire death row be kept at a heat index at or below 88 degrees. The trial court reasoned that the three plaintiffs can be moved to any cell, and thus, the entire cell block needed to be kept cool.
The State appealed the decision. The U.S. Fifth Circuit agreed with the trial court that the Eighth Amendment rights of the three plaintiffs have been violated, but overturned the injunction, finding that the trial court abused its discretion by providing an unnecessary type of relief that applied beyond the three plaintiffs. The Fifth Circuit found that the State only has to take measures to keep the three plaintiffs cool who each have medical conditions exacerbated by heat, and that this task could be constitutionally achieved by providing access to fans, ice, and cool showers. The Fifth Circuit ruled that the state does not have to provide air conditioning to the entire death row which would have benefitted many prisoners who do not suffer from medical conditions.
Ball, et al. v. LeBlanc, et al. (5th Cir. 2015)