Razor wire is seen below a guard tower along the perimeter of a yard, Wednesday, September 3, 2025, at Louisiana State Penitentiary in Angola, La.
A federal appeals court has found that prisoner health care at Louisiana State Penitentiary at Angola met standards set by the Eighth Amendment, overturning a lower court’s 2023 order that would have required the prison to make certain improvements.
The Department of Corrections had already made many of the improvements sought by prisoners and their advocates during the nearly 11 years since the class action suit was brought against the state, Judge Edith Hollan Jones, of the U.S. Fifth Circuit Court of Appeals, stated in the majority opinion handed down on March 30.
Jones criticized the lower court’s original ruling, which she said did not consider medical care improvements made at Angola prior to the court issuing its “remedial order” — or directions for the DOC to follow to ensure necessary improvements were made.
“The overall result of the district court’s orders, or failure to consider ongoing changes, is a mishmash of mandates, some of which are already rendered obsolete by events,” Jones wrote.
She pointed to an electronic medical records management system as one example of improvements made after the district court trial and before the court issued its remedial order months later.
A standard of “deliberate indifference” from a prison official is needed in order to constitute an Eighth Amendment violation. Jones argued in the majority that the indifference must be judged by prison officials’ current attitudes and conduct, not those from 2015.
“The Department of Corrections has always met constitutional standards for health care at Angola and has continually made improvements to both administrative systems and direct care,” Attorney General Liz Murrill said in reaction to the appeals court ruling. “The Fifth Circuit opinion recognizes and vindicates our repeated efforts to ensure we meet and exceed constitutional standards, which the district court judge simply refused, improperly, to acknowledge. We are grateful that after 12 years we are finally getting the legal recognition that DOC deserved all along.”
Not seeing a doctor until it’s too late
The case, Parker v. Hooper, originally was brought in 2015 by the Promise of Justice Initiative alongside Disability Rights of Louisiana after the organizations investigated claims of improper medical care at Angola for over a year.
The organizations got a class certified of prisoners who had suffered negative health outcomes they blamed partially on contracted medical staff at Angola not taking their concerns seriously.
Attorneys for the prisoners argued that many weren’t allowed to see a specialist doctor until their conditions had already deteriorated to the point of being terminal illnesses — including multiple cancer diagnoses that weren’t made until the cancer had already entered a late stage.
In one example, a 50-year-old inmate died from a large liver abscess that had been compressing his spinal cord, according to district court records. Prior to his death, the inmate made seven unanswered requests for medical attention due to back pain. He later became bedridden and incontinent and was found lying on the floor. When a doctor did see him, the inmate died within hours.
The district court’s 2023 ruling found the DOC violated the Eighth Amendment as well as the Americans with Disabilities Act.
In total, 17 prisoners made up the original plaintiffs when the class was certified. Samantha Pourciau, senior staff attorney for the Promise of Justice Initiative, said that only three of those prisoners are still at Angola. The rest have either died or been moved to other facilities.
Kentrell Parker, the case’s namesake, still survives, Pourciau said. He was a quadriplegic prisoner at Angola who was granted medical parole to a nursing home after seeking it from the DOC for many years.
"Every day at Angola, our clients are exposed to extreme and preventable health consequences due to the state's persistent neglect and indifference,” Pourciau said. “As the dissent recognized, this decision undermines the horrifying record of 'preventable deaths and significantly more unfathomable pain and suffering.' For example, a 28-year-old man in solitary confinement called for help but was not given treatment until eight hours later when he was found dying on the floor — facts the state itself never disputed. We will continue fighting to prevent further atrocities for people who deserve their humanity to be acknowledged.”
The district court split its original ruling into two parts, with a separate trial for each. First, the judges found the DOC was liable and improvements were needed. Then they ruled on what those improvements would need to be and how they would be made, producing the “remedial order” for Angola to follow.
The Fifth Circuit’s ruling only took issue with the remedial order and how it was carried out, with much of the majority opinion focusing on how the order didn’t follow guidelines set in the 1996 Prison Litigation Reform Act.
One complaint involved the fact the lower court had ordered Angola to allow three experts — being paid by the state — to tour the facility and request records to ensure improvements were made. The Prison Litigation Reform Act requires only one expert, who cannot be paid by the state.
“Any court-appointed master will be striking at straw men, needlessly interfering with prison authorities’ duties and running up bills for no constitutional remedial purpose,” Jones said in her majority opinion.
The lower court’s ruling on Angola’s liability wasn’t overturned by the Fifth Circuit, however, leaving the door open for the class action to return to the district court and for prison advocates to argue that changes at Angola have not fully remedied the issues at hand.
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