Elzie Ball v. James LeBlanc
2015 U.S. App. LEXIS 11769
5th Cir.2015Background
- Angola death-row facility lacks air conditioning; inmates allege Eighth Amendment violation due to extreme heat and preexisting medical conditions.
- Three inmates Ball, Code, and Magee reside on tiers A and H; they suffer hypertension, diabetes, obesity, hepatitis, depression, and high cholesterol.
- Prisoners filed complaints alleging heat exacerbates health conditions; ADA and RA claims denied by district court.
- USRM monitored temperatures from mid-July to early August; heat indices often exceeded 100°F on the relevant tiers.
- District court found Eighth Amendment violation based on substantial risk and deliberate indifference, and ordered a plan to keep heat index at or below 88°F, effectively requiring air conditioning.
- Court later vacated the injunction and remanded for narrower relief consistent with PLRA and Gates v. Cook.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether heat conditions created a substantial risk of serious harm under the Eighth Amendment | Plaintiffs show heightened vulnerability due to medical conditions | State argues risk is not substantial; past incidents and medical records show no current harm | Yes; district court did not clearly err in finding substantial risk and deliberate indifference |
| Whether defendants’ knowledge of risk satisfied deliberate indifference under Farmer/Wilson | Total record shows officials knew of and ignored risk | Administrative complaints alone insufficient proof | Yes; record supports deliberate indifference beyond administrative remedies |
| Whether thermoregulatory impairment constitutes a disability under ADA/RA | Thermoregulation is a major life activity/major bodily function causing disability | No evidence that thermoregulation is impaired in plaintiffs; prior definition superseded | Harmless error; no evidence of impairment to thermoregulate adequate to prove disability |
| Whether injunction complies with PLRA and Gates in scope and targets | Facility-wide air conditioning is necessary relief | Relief should be narrow and tailored to plaintiffs; not facility-wide | Remand for narrower, plaintiff-specific relief consistent with PLRA and Gates; vacate facility-wide injunction |
Key Cases Cited
- Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) (increased ice, water, showers when heat index high; distinguishable from current case)
- Helling v. McKinney, 509 U.S. 25 (U.S. 1993) (unreasonable risk of future harm actionable under Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard in prison conditions cases)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (requires subjective knowledge of substantial risk for liability)
- Brown v. Plata, 563 U.S. 493 (U.S. 2011) (PLRA scope and relation to court orders in prison conditions)